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Advocacy Corner – November 2024 – January 2025 update

Following a busy end to 2024, the policy team has had an equally hectic start to 2025!

There are several consultations currently underway that will have a significant impact on the telecommunications sector. Namely, the review of the Telecommunications Consumer Protections Code by Communications Alliance, as well as rules for the telco sector under Security of Critical Infrastructure Act. These subordinate rules will apply to carriers and carriage service providers that have over 20,000 services in operation or supplies to the government. If this is you or your organisation, then we highly recommend you attend the Town Hall that the Department will be running on 11 February to find out more information and ask any questions. You can read more about the open consultations below, and let us know if you have any concerns you’d like us to include in our submission!

The policy team has also had its hands full onboarding our new PPAP members! We received a record number of applications, and you can read more about our new PPAP members in this newsletter item. The interest in PPAP is a testament to the growth of the advocacy work that IAA has been doing to improve policy for the telco sector, and we thank all our Members for their interest in and support of our policy work. PPAP meetings are open to guests, so please let us know if you would like to attend. We will also provide regulatory updates at each in-person event this year, so make sure to attend!

As always, please get in touch to share your thoughts on any of the open and/or previous submissions below. We really appreciate your input.

Open consultations:

Telecommunications Service Provider (Customer Identity Authentication) Determination 2022 | ACMA | 14 February 2025

The ACMA proposes to amend its requirements related to identity verification. Proposed changes include the introduction of new authentication methods, the removal of biometric data as a primary authentication method, exceptions to sending notifications about high-risk transactions and record keeping requirements.

Consultation on Subordinate Legislation to the Cyber Security Act and Security of Critical Infrastructure Act 2018 | Department of Home Affairs | 14 February 2025

Following amendments to the Security of Critical Infrastructure Act, and the passage of the Cyber Security Act in late 2024, the Department of Home Affairs is consulting on various subordinate legislation related to rules governing the new Cyber Incident Review Board, ransomware reporting requirements; security of smart devices, data storage systems as a critical infrastructure asset, and most importantly, the risk management program rules for the telecommunications sector. All carriers and CSPs with 20,000+ active services in operation or those that knowingly supply to government will be subject to the positive security obligations, including the risk management program rules.

C628: Telecommunications Consumer Protections Code Review | Communications Alliance | 28 February 2025

Communications Alliance is conducting its periodic review of the TCP Code, and the latest iteration is now open for public consultation. The TCP Code is a significant instrument that applies to most of IAA’s Members. There are many proposed changes, including enhanced rules regarding the identification and protection of vulnerable customers, providing at least 2 fee-free payment methods, the requirement to perform credit checks for consumers for contracts that could result in a debt of +$150, providing a (near) real time customer support channel, flexibility regarding direct billing payments, and compliance processes.

Completed submissions:

Member Guidance – Reasonable steps to inform consumers and occupiers of IDR and EDR | TIO

 Scams Prevention Framework Bill | Treasury

SLAID Act Review | INSLM

NBN Co Amendment (Commitment to Public Ownership) Bill 2024 | Senate Standing Committees on Environment and Communications

Unfair Trading Practices Consultation Paper | Treasury

Online Safety Amendment (Social Media Minimum Age) Bill 2024 | Senate Standing Committees on Environment and Communications

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