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Advocacy Corner – May to July 2023

IAA Advocacy Corner

Things continue to be busy for the policy team. Over the past couple months, we’ve been involved in the NBN Co SAU (Special Access Undertaking) variation process which will hopefully come to a close by the end of the year. NBN Co will be submitting an updated SAU later this month, and hopefully, this iteration will be acceptable.

We had our quarterly Public Policy Advisory Panel (PPAP) meeting to discuss some recent and upcoming regulatory changes, where PPAP members expressed particular concern over the recent calls from the Australian Communications and Media Authority (ACMA) and Telecommunications Industry Authority (TIO) for direct regulation of consumer protections. In case you missed it, the Minister of Communications has since supported this and we will be working with ACMA to develop a Financial Hardship Standard in the months to come.

Our Policy Officer presented at the inaugural Comms Day Policy Forum, and you can read more on that in the next item. Also check out our article on the recently registered Online Safety Code, including our guidance material that we created to assist members in unpacking and implementing compliance requirements.

As always, please get in touch to share any thoughts on any open and previous submissions; we always appreciate your feedback.

Completed Submissions:


There have been several consultations surrounding the NBN Co SAU. The Australian Competition and Consumer Commission (ACCC) indicated it would reject the November 2022 iteration. We supported its call for improvements to NBN Co’s commitments to benchmark service standards as well as pricing certainty.

NBN Co has focused specifically on pricing methodologies for lower speed tier services (50 Mbps and under), and is currently reviewing feedback on its “floor and ceiling” approach which would introduce a cap on the overage (fixed to the amount of the 100Mbps service) and baseline while removing aggregate CVC utilisation across bundled services to give a pooled overage calculation. NBN Co maintains this will level the playing field for smaller Retail Service Providers (RSPs) who lack the resources to optimise its customer base to take advantage of CVC pooling.

You can read our response to each of the consultation papers below:

Draft Decision: Variation to the NBN Co Special Access Undertaking (Nov 2022) | ACCC

NBN Co SAU Further Targeted Response | ACCC

NBN Co SAU Modified Floor and Ceiling Proposal | ACCC

Telecommunications Consumer Protections (TCP) Code | Communications Alliance

Comms Alliance has started the review of the TCP Code, which is currently in the first stage of information gathering. In our response, we emphasised the need for a balanced Code that takes into account the cost of compliance for ISPs while noting industry’s recognition of the importance of protecting consumers.

Draft CRIS for 2023-24 | ACMA

In response to the ACMA’s Draft Cost Recovery Implementation Statement, we noted the need for greater transparency and information sharing to provide greater assurance and accountability with regards to their provision of services.


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