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ACCAN has submitted to the ACCC’s inquiry into NBN’s wholesale service standards. The purpose of the inquiry is to determine whether NBN wholesale service standard levels are appropriate, and to consider whether regulation is necessary to improve customer experiences.

ACCAN has long advocated for reform of existing customer service guarantees for connection times, fault repairs and network reliability. Currently, nbn’s wholesale service standard levels are set out in commercial agreements negotiated by nbn co with retail service providers (nbn’s Wholesale Broadband Agreement). This includes performance objectives and operational targets for nbn co’s products and services, requirements for improvements if targets aren’t met, and an arrangement that allows service providers (nbn’s wholesale customers) to claim compensation for their customers when nbn has failed to meet a service target.

Telecommunication services have always been essential for public health and safety, but today they are a necessity for participation in civic society and transacting with government, for business operations, productivity and growth. ACCAN’s Pre-Budget Submission 2018-19 discusses market gaps and gives recommendations on telecommunications initiatives that will benefit consumers including:

The process for migrating to the NBN is set out in a document called the Migration Plan. The Migration Plan needs to be tailored with each new technology that nbn uses in its network. In this consultation, Telstra has proposed a number of changes to accommodate the Fibre to the Curb (FTTC) technology. nbn plans to use FTTC to connect about one million Australian premises from 2018.

The ACCC is conducting a Communications Sector Market Study, and has consulted on its draft report following its consultation last year on an Issues Paper. The ACCC’s draft report made a number of recommendations and proposed actions to improve telecommunications market and services for consumers over the next 5 years, which adopted many of the suggestions flagged in our Issues Paper submission.

In consultation with its members and other consumer groups, ACCAN responded to the ACMA’s consultation on the potential for industry self-regulation of the IPND, DNCR, and spam.

ACCAN believes it is in the consumer interest that functions of the IPND, DNCR, and commercial electronic messages are not referred to industry for regulation. 

Passing regulatory functions currently undertaken by government to industry could have detrimental privacy and cost implications. It also has the potential to impact on complaints handling, enforcement and compliance, and the transparency over the ways in which these activities are undertaken.

The Department of Communications and the Arts recently commenced a review of Australia’s management of the .au domain by the Australian Domain Authority (auDA). ACCAN submitted its comments on the management framework of auDA and ways to ensure the .au domain continues to serve the needs of the online Australian community.

Communications Alliance, the communications industry peak body, is proposing to deregister and repeal the Call Charging and Billing Accuracy Code (C518). This Code sets out requirements for providers to test the accuracy of their call charging and billing for the standard telephone service (STS).

ACCAN believes the Code contains important detailed provisions to support accurate billing, such as requiring providers to develop and implement a test plan; to use performance indicators for accuracy testing; and compliance reporting requirements. In our submission, we acknowledge that the Code may have declining applicability, but argue that its principles are still relevant. It is important that consumers have confidence that their billing is correct, and reflects actual usage.

Complaints data from the Telecommunications Industry Ombudsman (TIO) illustrates that billing for communications services is a significant consumer issue, with 41.9% of the 2016-17 financial year complaints relating to billing and payments.

ACCAN and Internet Australia have jointly submitted to industry peak body Communications Alliance’s consultation on the deregistration and repeal of the End to End Network Performance for the Standard Telephone Service (STS) Code.

The Code sets out technical rules for the performance of standard voice services. These rules mean that voice services operate within acceptable standardised levels of echo, delay and loudness, supporting positive consumer experience. Our submission argues that consumers both need and deserve the high quality of voice telephony supported by the Code.

Communications Alliance considers that C519 no longer holds currency and practical value due to frequently evolving telecommunications technology and the declining use of the STS, and the current scope of the Code.

ACCAN provided comments to the Communications Alliance on the Prepaid Calling Card Guideline. The original purpose of the Guideline was to ensure that consumers were adequately informed when making a decision on which calling card to buy. ACCAN submitted that the current Guideline no longer achieves this purpose and that its objectives should be redrafted to reflect its actual content. This is because a 2015 review of the Guideline removed a majority of content that was replicated in the Australian Consumer Law and by the Telecommunications Consumer Protections Code. The Guideline now only contains two sections; one on Emergency Services Requirements, and another on general rules. ACCAN submitted that if the Guideline were to be withdrawn, it should be on the condition that these two sections are moved to a new enforceable instrument.

The Australian Competition and Consumer Commission (ACCC) has powers to request information from providers in the telecommunications market about telecommunications infrastructure. These powers are an important tool to inform the ACCC’s work. As an example, the ACCC could use these powers to request information about infrastructure like the mobile networks owned by Telstra, Optus and Vodafone.

The ACCC is consulting on improvements and revisions to the information it requests from telco infrastructure providers. ACCAN welcomes the proposed changes to these rules as they benefit competition in the telecommunications markets.

Recently, auDA, the body responsible for Australia’s domain name system agreed to introduce ‘direct registrations’. This is where your chosen internet domain name does not use the familiar “”, “”, “”, and new names will be simply “”.

Many Australian not-for-profit organisations and businesses currently have domain names for their internet presences under the second level domains. For example: * and * Domain names are used to find resources and services on the internet such as web pages (eg and email addresses (This email address is being protected from spambots. You need JavaScript enabled to view it.).

ACCAN contributed to the Financial Rights Legal Centre’s  joint consumer submission on the Review of the Privacy (Credit Reporting) Code 2014 (CR Code). The other contributors included the Australian Privacy Foundation, the Consumer Action Law Centre, the Consumer Credit Legal Service (WA), and Financial Counselling Australia.

The CR Code makes up part of Australia’s credit reporting scheme, and is important as it strengthens consumer privacy protections.  The joint consumer submission makes 34 recommendations on a wide range of consumer issues including: Repayment History Information and financial hardship; the need for independent code governance; the inclusion of credit scores on free credit reports; ongoing problems with accessing free credit reports; and many others.