ACCAN’s Executive Summary of Response to NBN Co’s Consultation Paper 2

Details

The Australian Communications Consumer Action Network (ACCAN) is pleased to provide this submission on NBN Co Ltd’s (NBN Co) 2025 Replacement Module Application (RMA) Consultation Paper 2 (the Paper) as part of NBN Co’s compliance under the economic regulation regime established by the August 2023 Variation of the Special Access Undertaking (SAU).

NBN Co’s Consultation Paper 2 covers two key work programs, representing both investment in its future potential, as well as shoring up its existing network. It is the second of two public Consultation Papers that NBN Co has released as part of its RMA process and is the last opportunity for public consultation before NBN Co submits its proposal by 2 July 2025.

At face value, ACCAN considers that many aspects of NBN Co’s work proposals in fibre migration and service standards appear reasonable and beneficial for consumers, including fibre upgrades and improvements to benchmark service standards, to ensure that Australians can reliably access government, health, economic and educational services.

However, ACCAN considers that there are substantial gaps in the paper which NBN Co needs to address in order to meet the long-term interest of end-users (LTIE). ACCAN therefore recommends NBN Co:  

  • Articulate a clear and comprehensive strategy for advancing fibre migration.
  • Genuinely engage with consumers and consumer advocacy groups on expenditure forecasts.
  • Streamline and revise service standards to promote their efficacy and improve compliance.
  • Apply uniform service standards regardless of geographic location.
  • Overhaul the rebate system to ensure complete passthrough to consumers.
  • Engage with consumer advocacy groups about upgrades to satellite services.

Based on the information provided to date, ACCAN is unable to determine whether NBN Co’s expenditure reflects value for money for consumers sufficient to justify the likely price increases that these work programs will generate.

We therefore recommend NBN Co undertake significant work, including with industry and consumer advocacy stakeholders, to ensure that a compliant RMA is submitted by 2 July 2025.

Download: pdfExecutive Summary of ACCAN Response to Consultation Paper 2631.2 KB