No 24: 31 October 2023



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Draft Proposed Financial Hardship Standard Release

Communications Alliance notes the draft financial hardship standard released for consultation by the Australian Communications and Media Authority (ACMA) and will work with the regulator in pursuit of operationally feasible outcomes for consumers across the spectrum of telecommunications consumer protection needs. 
Communications Alliance CEO, John Stanton, said it was important that the standard be capable of implementation, but also that it meshes effectively with the broad range of additional protections in the enforceable industry code (the Telecommunications Consumer Protections, or TCP code) that is currently being revised and strengthened by Comms Alliance and its members. 
“To be capable of producing better outcomes for customers in financial hardship, the standard must contain requirements that service providers can put into effect – particularly given the potential need for changes to IT systems and business processes, the tight timeframes that the ACMA is proposing and the fact that the industry’s ability to make back-end changes is normally constrained over the end-of-year holiday season, 
“Key service provider representatives are already deeply engaged in the revision of the TCP Code – a process also subject to a tight ACMA-mandated deadline, 
“Nonetheless, we will work constructively with the regulator to try to ensure that the standard, once in place, provides additional net benefits to customers, 
“It is worth noting that the cost of telecommunications services are not rising in real terms and are not among the top five factors affecting cost of living increases for Australian consumers,” Mr Stanton said.

Communications Alliance Response to ACCAN’s Call for Direct Regulation in the Telecommunications DFV Arena

Communications Alliance CEO, John Stanton, has offered a different perspective on the challenges to ensure that consumers experiencing domestic or family violence (DFV) can receive assistance from their telecommunication provider. The comments came after the Australian Communications Consumer Action Network (ACCAN) called for direct regulation as a solution.

“ It’s disappointing that ACCAN has defaulted to a “one-size fits all” cry for direct regulation to assist telecommunications consumers who may be experiencing domestic or family violence (DFV).

“It was industry that initiated the work in this space six years age through the creation of an industry guideline to help service providers to use flexible tools to help consumers who may be at risk.

“This was followed by a much improved and strengthened guideline – created collaboratively with community organisations and DFV support agencies and completed in 2023.

“Industry agrees that core elements of the guideline should be enforceable - and that action is in train through the incorporation of parts of the guideline into the Telecommunications Consumer Protections (TCP) industry code.

“We also agree that enforcement of those obligations should be made more rapid and agile if breaches occur. Indeed, we have put forward a proposal to achieve that improved enforcement capability for the regulator – a proposal ACCAN has not responded to.

“Direct regulation in an area as complex and sensitive as DFV risks preventing the flexibility that service providers often need, in order to respond to the individual circumstances and challenges that consumers can face, “ Mr Stanton said.

Reviewing Voice Performance Standards and Regulations for Telephony Devices

Communications Alliance is seeking comments on our AS/CA S004:2013 Standard for voice performance requirements for customer equipment. In addition to the general review of the Standard, we are seeking specific comment on the applicability of this Standard to devices connected to the telecommunications network - devices traditionally thought of as telephone devices, as well as other connected devices; examples being videoconference units and gaming consoles. We are also reviewing the acoustic safety requirements, including those specifying acoustic shock, maximum signal levels and frequency ranges.

Further information can be found on the Communications Alliance Documents under review webpage. Submissions are due by 5 p.m. on Monday 20 November 2023.

Current Consultations

Below is a list of currently open telecommunications-related consultations being conducted by Government and other organisations that provide an opportunity for you to have your say.

Communications Alliance members interested in contributing to an industry submission (if one is being developed in response to a specific consultation) should contact us.

Organisation/Closing Date

CDITRDCA - 1/03/2024

DITRDCA - 8/12/2023

DITRDCA - 30/11/2023

Treasury - 29/11/2023

ACMA - 27/11/2023

ACMA - 24/11/2023

ARCA - 16/11/2023

DITRDCA - 8/11/2033

Dept of Finance - 31/10/2023

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Contact Tel: (61) 2 9959 9111