Sydney, 14 July 2021 – Communications Alliance welcomes the ACMA’s release of a consultation paper about consumer vulnerability and its report on the results of an audit of telco approaches to assisting vulnerable customers.

Communications Alliance CEO John Stanton said, “while industry’s Telecommunications Consumer Protections (TCP) Code sets minimum standards for service providers, we are pleased to see the ACMA leading the conversation on options telcos can use to implement better practice at their organisations.

“Assisting consumers who may be experiencing vulnerability is an important part of providing any essential service, and there is constantly evolving thinking on how this can best be done,” Mr Stanton said.

“As to the obligations telcos must comply with, the audit showed that some are going above and beyond compliance requirements, with forward thinking practices, while others were made aware of improvements they needed to make.

“We look forward to working with the ACMA on further developing the information on better practices set out in the Statement, and on how we and the ACMA can better educate telcos on their obligations and provide clear tools and guidance on how to meet those,” Mr Stanton concluded.


The Telecommunications Consumer Protections Code (TCP Code) is an industry Code, enforced by the ACMA, that provides consumer safeguards in the areas of sales, service and contracts, billing, credit and debt management and changing suppliers.

It includes a number of specific obligations on telcos to assist and protect disadvantaged and/or vulnerable consumers.

These include the following, as laid out in the ACMA's draft Statement of Expectations:

Dealing with the disadvantaged and vulnerable (clause 3.4): telcos must have regard to best practice on dealing with disadvantaged and vulnerable consumers as set out in the ACCC’s Compliance Guide Don’t take advantage of disadvantage: a compliance guide for businesses dealing with disadvantaged or vulnerable consumers (the ACCC Guide). Telcos must also adopt best practice as set out in the ACCC Guide in their debt collection activities.

Systems, processes and training (clause 3.3): telcos must have and must regularly review systems and processes to support their TCP Code obligations and ensure staff are adequately trained in those systems and processes.

Responsible selling (clause 4.5.1): telcos must ensure their sales representatives adopt a responsible approach to selling that assists consumers to make informed purchasing decisions. To achieve this outcome, telcos must:

  • ensure sales representatives are appropriately trained to promote and sell in a fair, transparent, responsible and accurate manner;
  • monitor periodically to see how sales representatives interact with consumers and take steps to address deficiencies in sales conduct; and
  • ensure sales representatives are appropriately trained and have tools and aids to assist consumers to understand the telecommunications products they are purchasing.

Identifying and meeting consumer needs (clause 4.5.2): where a consumer identifies a particular need, telcos must advise if they have a product or service offering to suit the consumer’s identified need and provide information to allow the consumer to assess the suitability of the product or service to meet that need.

Authorised representatives (clause 3.5) and advocates (clause 3.6): telcos must ensure that a consumer can appoint an authorised representative or an advocate to act on their behalf.

Responsible provision of telecommunications products (clause 6.1): telcos must have appropriate credit and debt management processes, including by conducting credit assessments at the point-of-sale to prevent consumer over-commitment and providing advice about alternative products where the consumer is unable to meet the financial commitment.

Spend management tools (clause 6.5.): telcos must provide spend management tools and make information about these tools available in an accessible manner at no cost.

Notice to restrict, suspend or disconnect (clause 6.7): telcos must provide customers with adequate notice of any restriction, suspension or disconnection of a service for credit/debit reasons.

Financial hardship (clause 7.1): telcos must provide access to financial hardship assistance, including by having financial hardship policies that are easy to find and provide consumers with options to enable them to stay connected, and meet financial obligations.

Communications Alliance is the primary telecommunications industry body in Australia. Its membership is drawn from a wide cross-section of the  communications industry, including carriers, carriage and internet  service providers, content providers, search engines, equipment vendors, IT companies, consultants and business groups.

The most influential association in Australian communications, co-operatively initiating programs that promote sustainable industry development, innovation and growth, while generating positive outcomes for customers and society.  To create a co-operative stakeholder environment that allows the industry to take the lead on initiatives which grow the Australian communications industry, enhance the connectivity of all Australians and foster the highest standards of business behaviour.  For more details about Communications Alliance, see

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