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We’re proud to share that Narelle Clark, CEO of the Internet Association of Australia, has been officially inducted into the CommsDay Hall of Fame.

Announced at the 2025 CommsDay Summit in Sydney in June, this honour celebrates Narelle’s decades of impact across consumer advocacy, internet infrastructure, and policy. Her work has helped shape a more connected, inclusive, and resilient digital Australia.

As CEO of IAA, Narelle continues to lead with insight, integrity, and purpose championing a stronger, more community-focused internet for all.

Congratulations, Narelle a well-deserved recognition!

Telecommunications providers must act now to ensure compliance with the below major regulatory changes coming into force from as early as 30 June 2025:

  • Telecommunications (Consumer Complaints Handling) Industry Standard Amendment 2025 (No. 1) – Commencing 30 June 2025
  • Telecommunications (Customer Communications for Outages) Industry Standard Variation 2025 – Commencing 30 June 2025
  • Telecommunications (Domestic, Family and Sexual Violence Consumer Protections) Industry Standard 2025 – Commencing 1 July 2025

We have updated template packs provided on the IAA Member Portal to assist Members with their compliance obligations, but it is important Members understand new requirements arising from recent regulatory reform.

1. Expanded Complaints Handling Framework

From 30 June, telco providers will have to comply with new obligations in relation to handling complaints from consumers including:

  • New “Network Outage Complaint” Category:
    A new “network outage complaint” is now explicitly defined to align with the Telecommunications (Customer Communications for Outages) Industry Standard 2024. If a consumer reports loss of service and the provider suspects a network outage is occurring (either a major outage or significant local outage), the report must be treated as a formal network outage complaint
  • Network Outage Complaints Handling Process:
    Providers must establish a separate, documented process for handling network outage complaints and publish it on their website. IAA’s Template Complaints Handling Policy has been updated to include network outage complaints, and is available on the IAA Member Portal.
  • Resolution Standards for Network Outage Complaints:
    A network outage complaint is resolved once:
    • Service is restored, and
    • A bulk resolution offer (e.g. compensation or credit) is communicated (if offered)
  • Natural Disaster Exclusion:
    Complaints related to outages triggered solely by natural disasters may be handled through standard complaint processes instead.
  • Improved Accessibility:
    The ACMA have also introduced other changes unrelated to network outage complaints in relation to making complaints and complaints handling process more accessible. This includes, amongst other things, maintaining a direct link on the telco’s homepage and the help or support section of its website to display a list or table of each of the contact details the provider makes available to receive complaints, along with a statement that these contact points can be used to make a complaint.

2. Enhanced Communications During Outages

The Telecommunications (Customer Communications for Outages) Industry Standard has also been updated to introduce obligations in relation to ‘significant local outages’, which commence 30 June. Please note, obligations already exist in relation to ‘major outages’.

Variation Highlights:

  • New defined term – ‘significant local outages’
    ‘Significant local outage’ is defined as unplanned adverse impact to your telco network that results in an end-user unable to establish and maintain a carriage service which affects:
    • ≥1,000 SIOs in regional Australia for a period of over 6 hours;
    • ≥250 SIOs in remote Australia for a period of over 3 hours.
  • Notification obligations in relation to a significant local outage
    Carriers and CSPs must notify and communicate with select persons and groups at different stages including initial notification, regular updates, updates of material changes, and service restoration. IAA provides updated template kits including template notifications and communications that carriers and CSPs can send out in relation to both major outages and significant local outages in the IAA Member Portal.
  • Written Procedures
    Telcos must update their public-facing Network Outage Communications Policy to include their procedures in relation to a significant local outage. A template policy is also included in the Template Kit provided by IAA.

3. New Protections for Persons Affected by Domestic, Family & Sexual Violence

ACMA has introduced a new industry standard to establish protections for persons affected by domestic, family and sexual violence. While the Standard commences from 1 July, telcos will have a longer timeframe to comply with many of the requirements. Below are only the compliance requirements that begin from 1 July:

  • Reversal of service limitation for affected persons (s 13(3)-(5)):
    If a service has been limited (e.g. suspended or disconnected), and the affected person urgently requests reversal due to a DFV safety risk, the telco must urgently reverse it on first contact, or offer an equivalent service if reversal isn’t practical. However, reversal isn’t required where doing so would breach another Commonwealth law (e.g. emergency call service obligations).
    Must not require affected persons to engage with perpetrator (s 15(1)):
    Telcos must not require a person affected by DFV to contact or interact with the perpetrator of the DFV or the perpetrator’s authorised representative.
  • Information about support offered (s 16)
    Telcos must publish information on their website about the support they offer to people affected by domestic and family violence. If they don’t yet offer specific support, they must publish contact details for external support organisations and indicate when their own support services will become available.
  • DFV Policy (s 19-20)
    Telcos must develop and implement a domestic and family violence (DFV) policy, that is approved by the telco’s most senior executive, and develop supporting procedures that meet specific standards. Large providers have 6 months, and small providers 9 months from 1 July to comply.
  • General DFV Training (s 21)
    All personnel must receive DFV training, which can be delivered internally or via an expert 3rd party. Large providers have 9 months, and small providers 12 months from 1 July to complete training, with annual refreshers of the training to be completed.
  • Specialised DFV Training for Customer-Facing Staff (s 22)
    Personnel in customer service, or likely to deal with DFV issues must complete specialised DFV training which covers applying the telco’s DFV policy and procedures, nature of DFV and its relationship to telco services, how to identify affected persons, intersectionality and DFV, engaging with affected persons, and recognising and prioritising safety of affected persons and the safety of personnel engaging with perpetrators. The specialised DFV training can be tailored to the role of the personnel, and may be delivered internally or via an expert 3rd party. Large providers have 9 months, and small providers 12 months from 1 July to complete training, with annual refreshers of the training to be completed.
  • Consultation requirements (s 32)
    From 1 July, telcos must consult with and consider feedback from DFV support services and either people with lived experience or organisations representing at-risk groups when developing DFV policies and procedures (s 19), and training (s 21-22). Large providers must consult directly; small providers may do so via an industry body.

    A large provider means a provider with at least 30,000 SIOs, and a small prover is a provider with less than 30,000 SIO.

Please note, IAA is considering whether and how to undertake the consultation requirements on behalf of our members that fall under the ‘small provider’ category. If you are interested in being represented by IAA, please let us know by contacting policy@internet.asn.au.

What Telcos Must Do

Compliance Area

Required Actions

Complaints Handling (30 June)

Update processes and policies to handle and display network outage complaints separately.

Update website to specify points of contact to make complaints.

Ensure staff are trained to appropriately handle any network outage complaints as such.

Network Outage Communications (30 June)

Update internal processes to ensure communications are sent in relation to significant local outages.

Update public facing policy to include communications processes in relation to significant local outages.

DFSV Protections (1 July)

Ensuring staff understand all obligations that will commence from 1 July that relate to persons affected by DFV – e.g. not requiring affected persons to contact perpetrators, reversing service limitations.

Updating website to specify support information.

Undertaking consultation requirements to develop DFV Policy, procedures and training.

Training staff.

If you have any questions about the any of the new regulation, please contact us at policy@internet.asn.au.

Written by: Sophia Joo | Senior Policy Officer & Company Secretary

⚡️Network Engineers & Internet Peering Enthusiasts, let's talk about something fundamental yet often misunderstood!⚡️

When we talk about the power and efficiency of the Internet, we often highlight Internet Exchange Points (IXPs) as critical interconnection hubs. And they absolutely are! However, it’s crucial to remember that a typical Internet Exchange fabric is a pure Layer 2 construct.

What does that mean in practical terms?

An IXP does NOT perform any routing for or on behalf of its peering participants.

Think of it this way:

It’s a giant, shared Ethernet switch. Your router connects to it, and its sole purpose is to forward Ethernet frames between connected participants’ routers based on MAC addresses.

Each participant is responsible for their own routing decisions. The IXP itself only influences which routes you learn from their route servers, or advertise via their route servers, based on things like attached control communities and RPKI ROA validity. This doesn’t include so-called “bi-lateral” BGP sessions with peering partners directly across the exchange, which are entirely free of IXP influence!

No IP forwarding tables, no MPLS labels, no routing protocols running within the IXP’s core fabric for participant traffic. Most IXP’s operational networks will have their own underlay routing, but that’s distinct from the participant traffic plane.

Why is this understanding critical?

– Troubleshooting: If you’re experiencing routing issues with a peer at an IXP, your focus should be on your BGP configuration, your router’s health, and the peer’s BGP configuration – not on the IXP “routing” your traffic incorrectly.

– Architecture: IXP peering is decentralised by nature. You’re effectively building direct relationships with others, not relying on a central router.

– Security: An IXP isn’t inspecting or manipulating your IP packets beyond some basic ingress filtering of “nuisance” traffic, to ensure the health of the exchange. Ultimately, the exchange simply provides physical and data link layer connectivity between networks.

– Performance: The beauty of Layer 2 is its speed and simplicity. It allows direct, low-latency communication between networks, which is exactly what IXPs want to give peers!

Next time you connect to an IXP, remember you’re essentially plugging into a massive switchboard designed for efficient, direct peer-to-peer conversations, not a traffic cop directing everyone’s data.

Written by: Matthew Kobayashi | IAA Peering Engineer

This month, we continue to be at the edge of the Internet talking about aspects of Traffic Engineering (TE) in BGP! We began our blog series by writing about TE – the what, the why, capacity management and traffic management. This month, we’re taking a look at outbound and inbound TE on the Internet, focusing on how BGP performs best path selection and some of the BGP attributes that make up the algorithm to determine the best path for packets.

Optimising traffic flow is something every good network engineer tries to achieve, and there are several ways that we can do this. An important issue that often occurs during peak times is traffic congestion. We don’t need to tell you about the issue with traffic congestion, but for end users, seeing that buffering symbol is just as disappointing as seeing the red ring of death on an Xbox! Let’s begin by looking at optimising traffic flow through the lens of outbound vs. inbound traffic.

Outbound vs inbound
As network experts, we know what outbound and inbound traffic is, so let’s skip ahead and talk about engineering it! Engineering outbound traffic is the process of manipulating the routing of traffic leaving our AS. By doing this, we can locally influence outbound traffic routes by adjusting BGP attributes, specifically local preference or AS path length. In comparison, engineering inbound traffic is much more complex and involves manipulating the routing of traffic coming onto our network. It involves adjusting the BGP attributes of routes advertised by peers, but don’t forget, peers can override these attributes when updates are sent, making it much harder. Now that we’ve covered the difference between outbound and inbound TE, let’s talk more about best path selection.

 

‘Okay BGP, show me the fastest route’
The BGP specification defines an algorithm known as best path selection to choose and install the best routes into routing tables. The algorithm uses a predefined set of criteria to select the most efficient route across the Internet to a destination address or prefix. The table below lists the order of criteria.

Priority Attribute
1 Local preference
2 Local origin
3 AS path length
4 Origin code (lowest)
5 MultiExit Discriminator (MED)
6 eBGP over iBGP
7 Shortest IGP path to BGP next-hop
8 Oldest path
9 Router ID
10 Neighbour IP address (lowest)

Now that we’ve looked at this broadly, let’s examine this a little further and look at the attributes that can be manipulated to determine the best path.

BGP attributes 
BGP protocol determines a score for each path based on attributes – these are the aspects we manipulate to make the BSP algorithm work the way we want it to. To better understand attributes, let’s split them into categories: mandatory, discretionary, optional transitive and optional non-transitive.  

Mandatory 
Mandatory: sounds demanding, doesn’t it? That’s because they are REQUIRED for routes to be considered valid. These are recognised by all BGP peers and are present in all update messages. These attributes are Next-hop, Origin and AS Path. 

Discretionary 
Discretionary attributes influence the algorithm but aren’t required for route validation. These are recognised by all routers, passed to all peers and can be included in update messages if required. These attributes are Local Preference and Atomic Aggregate. 

Optional transitive 
Optional transitive attributes can provide additional information about routes, but don’t generally affect the algorithm. They are possibly recognised by BGP routers and may be passed to other peers when received from a peer. These attributes are Aggregator and Community. 

Optional non-transitive 
The optional non-transitive attributes are Multi-Exit Discriminator (MED), Originator ID and Cluster ID. Non-transitive attributes received from a peer are not permitted to be passed to other peers by the receiving AS. 

In addition to attributes, asymmetric routing is also integral to quality TE.  

Let’s take a different route home 
Asymmetric routing is another important aspect of TE. This occurs when a packet travels from a destination down one path and takes a different path upon its return – it’s very common in BGP and you can’t avoid it! Generally, asymmetric routing doesn’t cause issues, but when it does, it’s usually causing issues with load balancing leading to suboptimal routing. This type of routing occurs when 2 available paths are present and contain the same number of hops; AS path length will not force a routing decision. Therefore, the algorithm moves to the next attribute in the priority stack. 

Asymmetric routing can also cause issues with stateful devices, such as firewalls: traffic flows returning via a different path than the one they departed on can arrive at a different device, and if the receiving device is not aware of the flow’s existence or has no matching entry in its state table, the incoming traffic is dropped: 

Something’s wrong, help!
Things are always great when they work, unfortunately that’s not always the case! When it comes to TE, there are some great diagnostic tools out there including looking glasses, RIPE Atlas, NLNOG RING and more. They help us to troubleshoot a variety of different network issues. Here at IAA, we use looking glasses wherever they are available to determine how a network (AS) directs traffic destined for a particular IP address or subnet. We also operate our own looking glass for each IX, which can help give a better understanding of the paths available to a particular destination via the IX (or, indeed, if a destination is NOT reachable via the IX). When a looking glass is not available (i.e. a network operator has not made one publicly available), tools such as RIPE Atlas are invaluable for observing the path that traffic takes out of a particular AS, and can be used to narrow down the probable point of any routing issues along the path from a given AS to the destination. 

Understanding the difference between outbound and inbound traffic engineering is crucial to optimising traffic flow over networks. As network engineers, understanding which attributes can be manipulated to ensure packets travel down the best path can help reduce traffic congestion, improve efficiency and reliability. If you’d like to learn more about how to improve network performance through outbound traffic engineering, stay tuned for next month’s ‘how to’ blog article!

Hoping for a nice, quiet summer for a change? Then the latest seasonal weather outlook is not for you! Once again it’s forecast that adverse weather events are likely to cause major disruption across Australia.   

IAA CEO, Narelle Clark, attended a meeting of the Communications Sector Group where Bureau of Meteorology senior climatologist Greg Browning presented Australia’s seasonal outlook for December 2022 to April 2023. The Bureau warns that while severe weather can occur at any time of the year, October through to April is the peak time for flooding, tropical cyclones, heatwaves, bushfires and severe thunderstorms. Indeed, that’s what lies ahead for us according to Greg’s snapshot of what we can expect.   

Here’s a few points:   

La Niña is likely to finish sooner than usual, meaning fewer heavy-rain events than last year in the east. However, eastern Australia’s soils and water catchments are still very full, so if there is any heavy rain, it will likely still result in flooding.  

With all the extra rain we’ve seen, a lot of plant growth has occurred. As things dry up over summer, there is a strong risk of grass fires in the central-west region of NSW, in southern QLD and in north-western VIC (and probably SA too).  

WA is going to have a long, hot summer, with a higher than usual rate of hot days, meaning a high likelihood of bushfires.  

Cyclone season is likely to start early (in December), and indications are that those cyclones will be strong.  

What does this mean for the telco/internet sector?  

We expect there to be no let-up in the level of disruption to services due to weather and bushfires. As such, it is important that organisations make sure their regional teams are geared up for rapid repairs in difficult locations, energy supply back-ups are primed and ready, and all those redundant routes are in place. It’s likely none of them will be redundant in the unnecessary sense of the word!  

Click here to see the slides from Greg Browning’s presentation. The nerds among you will enjoy the pretty graphs despite the unwelcome news😉

At IAA, we aim to help our members and the Internet industry mitigate communications vulnerabilities resulting from internal and external factors. We do this by sharing information about potential risks, paving the way for best practice to be developed and so reducing the impact on your organisation.   

We extend our thanks to Greg Browning and the Bureau of Meteorology for permitting us to reproduce the weather forecast content and to the Department of Infrastructure, Transport, Regional Development, Communications and the Arts, and the Communications Sector Group.   

 

The Telecommunications Industry Ombudsman (TIO) closed consultation for its 5-year independent review on 15 May. The consultation was primarily focused on its ability to meet the Australian ‘benchmarks for Industry Based Customer Dispute Resolution’, as well as other issues including its revised terms of reference, governance and authorising environment and engagement and outreach activities. In preparation for our submission, IAA’s policy team consulted with various industry representatives. The feedback we received from our members has highlighted concerns with the TIO’s management of consumer complaints, which seems to point to inherent issues with TIO’s cost structure and complaints escalation model.  

We establish from the outset that IAA recognises the value of the TIO and the fundamental role it plays in the industry. The TIO is an industry-based ombudsman with the charter to provide an independent and external dispute resolution service, giving consumers an avenue to raise complaints about their telecommunications provider, free of charge. Carriers and eligible carriage service providers are required by legislation to join the TIO scheme.  

The TIO reported it received 301,396 complaints in 2020-21. It is proud to announce that 90% of these were resolved at the referral stage. The ‘referral’ stage is the lowest level of complaints handling where the TIO allows the provider to directly resolve a customer complaint. If the dispute is unresolved at this stage, it will be escalated to the ‘agreement’ level where the complaint is handled through dispute resolution methods such as conciliation, and investigation. In cases where the consumer and provider cannot come to an agreement, the next stage involves the complaint being resolved by a preliminary view or decisions by the TIO.  

However, it should be noted that providers face greater costs as the complaints are escalated to higher levels. This has often resulted in cases where a provider will concede and provide the complainant with some compensation, even when the provider is not at fault. Some of our members have reported instances where even the TIO has acknowledged that the customer is in the wrong, but has advised the provider to give the customer some compensation anyway, as the costs for escalating the dispute to the next stage will be higher than the compensation amount. This points to inherent problems with the costs and complaints handling structure through which the TIO operates.  

Another issue that became glaring is that the TIO is often failing to follow its own terms of reference. Clause 2.20 of the TIO’s terms of reference provide that the TIO “…will only consider a complaint after the member has had a reasonable opportunity to consider the issues.” However, while resources promoting the TIO and their complaints webpages note that customers must first directly contact the provider, there is no mention that they must also give the provider an opportunity to consider the issue or respond. Even the TIO’s online complaint submission form does not include the requirement of allowing the provider an opportunity to consider the complaint directly, without the involvement of the TIO. 

A joint submission by consumer advocacy groups has also highlighted inefficiencies with the TIO’s complaints handling mechanisms. Making 19 recommendations to improve the operation of the TIO, some of these points seem to be harmonious with the concerns raised by industry. 

For example, the joint submission calls for a differentiation to be made between simple complaints that can be resolved in a substantially shorter period (5 working days instead of 10). However, as noted in IAA’s submission, a large number of the complaints resolved via referral are disputes which should not have been dealt with by the TIO at all. If the requirement that a provider is given a genuine opportunity to respond is adhered to, the TIO would likely see a significant drop in dispute cases, resulting in a much more efficient process for everyone involved. 

Recommendation 3 of the joint submission also outlines that the TIO should ensure its intake processes thoroughly assess the root cause of the complaint. This is a concern similarly raised by industry where it seems the TIO often fails to understand the underlying cause of the problem. In our submission, we raised the TIO’s lack of knowledgeable triage which has resulted in a large number of complaints being raised against the incorrect provider. This has especially been the case where retail providers are being blamed for issues that lie with the wholesale providers. 

The coalition of consumer representative bodies has also called for an expansion of the TIO’s public reporting. Industry has similarly called for greater transparency and in-depth reporting. IAA noted the lack of clarity in the TIO’s 2020-21 Annual Report, particularly in relation to the TIO’s costs and revenue allocation. Given the overall decrease in the number of complaints made from previous periods to 2020-21, the increase in costs and expenses of the TIO in this same period should be explained. 

However, it is worth noting that the data requested by the consumer advocacy groups include the technology types, geographical location, and the TIO members involved in the complaints.  While IAA supports the call for greater transparency and detail in the TIO’s reporting in general, we disagree that the providers involved in TIO complaints should be publicised. Especially under current circumstances where it seems providers are being involved in disputes that either should not be dealt with by the TIO or concerns other providers entirely, this sort of ‘name and shame’ tactic seems particularly unfair. 

IAA, our members, and the telco industry recognise the value of an industry ombudsman. We acknowledge its necessity for the functioning of a healthy and thriving sector and wish to see consumers having an appropriate and effective mechanism through which they can bring genuine complaints. However, it is clear there are inherent issues that require some major improvements if the Telecommunications Industry Ombudsman is going to succeed in this role.  

Read IAA’s full submission

After much internal anticipation, research and writing, we are happy to launch our very own blog next month! With a prospective launch date of Friday, October 15, 2021, be sure to keep an eye out on our socials for the announcement of our very first blog post.   

As an organisation that operates for the benefit of the Internet and the people who build and operate it, we have decided that a monthly blog post providing an expert opinion on hot topics relating to the Internet would greatly benefit members.   

If you haven’t already, connect with us on our social media channels: Facebook, LinkedIn and Twitter to get all the latest blog posts, share your thoughts on the topic, and let us know which topics you would like us to cover.   

Happy international smile day! To mark this day, we would like to share with you a snippet from one of our newsletters in ’97 about the use of emoticons.

April 1997
EMOTICONS

———

These are “emotion icons” and are used to convey feelings in such things as email and postings to newsgroups, just to name a few. The standard smiley : ) usually conveys happy bright feelings with
whatever was said. For instance, Australians seem to use insults to convey how much they like someone, but when used in email, especially if being read by someone who is feeling a bit niggley, “you old so and so” can be taken as a real insult. The addition of a smiley, “you old so and so. : – )” lets the reader know how the other person intended the email to read.

Then there are these <G> or *G* for a “grin” or sometimes even <grynne> and yet again, these <BG> <EG> <VEG> <VBG> representing big grin, evil grin, very evil grin, and a very big grin. I even know of someone who might qualify for <VBEG> – a very big evil grin.

Other emoticons are: : – D laughing, : – 7 wry, : – > sarcastic, : – P cheeky, ; – ) winking, : – o shocked. There are many variations, and experimentation can produce some pretty clever comments in themselves.

Annette

:) :-D :P

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