No 26:  29 November 2023

Comms Alliance Concerned by Fine Detail of Proposed Hardship Standard

Communications Alliance has warned against potential consequences of a proposed new standard for telco customers in financial hardship.

The Australian Communications and Media Authority is currently consulting on the Telecommunications (Financial Hardship) Industry Standard 2024, which would mandate obligations around providing services to customers who cannot afford to pay for them due to hardship.

Comms Alliance says in a new submission that it is keen to work “constructively” with ACMA on the new standard, particularly to ensure it meshes with the Telecommunications Consumer Protection Code, currently undergoing revision.

“One overarching observation is that industry finds the draft standard to be highly prescriptive – to the point where it risks bombarding and/or confusing customers and driving them away from the assistance process; whereas those same customers might be readily helped by the type of lighter-touch methods that many carriage service providers already use,” the submission says.

Comms Alliance thinks commentary about the low number of telco customers on formal financial assistance arrangements is misleading, because it “ignores the wide range of less formal assistance and flexibility options that CSPs currently offer to customers when those customers experience challenges in paying for the services they have chosen to purchase.”

The industry group says that any expected actions required by the standard should reasonably balance the needs of a consumer and their ability to pay, against the telco’s right to be paid for services it provides and “take reasonable and proportional action to prevent further debt accruing and to recoup monies owed.”

“It is important to recognise the need to avoid imposing a standard that might – due to cost, inflexibility or other factors, act to disincentivise the commendable commitment of CSPs to less formal forms of assistance, or, perhaps more critically, inadvertently cause harm to customers by forcing them to choose between no assistance or a formal scheme that will flag the customer as a financial risk when they attempt to apply for credit in the future,” Comms Alliance says.

Among specific issues with the proposed draft standard raised by Comms Alliance are an ambiguity over whether it extends to business, non profit groups and even government, as well as the potential for customers to abuse the proposed arrangements. Specifically, Comms Alliance says: “there is no apparent limit on the length of time that a customer can deem themselves to be “discussing options” – leaving the door open to abuse of the framework if a customer refuses to pay for services indefinitely on the grounds that they assert they are still in the processing of discussing options.  This should be amended to provide greater clarity.”

Reprinted from CommsDay, 28 November 2023

Industry to Assist Bean Review

Communications Alliance will seek to assist the post-incident Bean Review announced by the Federal Government, alongside the process-analysis that many service providers are already undertaking.

Comms Alliance CEO, John Stanton, said the announced terms of reference are broad and the timeframe for the review is challenging.

“The review team will doubtless appreciate that the interdependencies within the sector are complex, but typically robust. This is because such interdependencies have chiefly been developed by industry through deep operational experience and collaboration nationally and globally.

“It is important to remember that Australia has one of the most advanced and best performing array of communications networks amongst our peers.

“Major incidents of any nature are an opportunity to analyse the potential for improvements to the current framework of resilience and communications responses. We will, of course, work collaboratively with all stakeholders and provide advice to government where we think processes can be optimised.” 

Scams Awareness Week 2023

Scams Awareness Week is an annual scams awareness raising campaign run by the ACCC on behalf of the Scam Awareness Network (SAN).  This year will be the first delivered by the National Anti-Scam Centre.

This year's campaign will run from Monday 27th November 2023 - Friday 1 December 2023. The theme for this campaign is ‘impersonation scams’. For further details click here.

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.