Telecommunications (Complaints Handling Industry Standard Amendment) Direction 2024

The instrument centrally concerns regulatory prescription of complaints-handling standards for telecommunications providers, with emphasis on outage-related consumer contacts, prioritisation, accessibility and transparency. The statutory mechanism is a ministerial Direction to the regulator to amend an existing industry Standard under the Telecommunications Act 1997 (s 3; s 5(1)). The Direction sets objectives the amended Standard must give effect to (s 6(1)) and enumerates possible content elements the amendments may include (s 6(2)).

Key defined actors and terms in the instrument include:

• ACMA, the regulator, which is directed to amend the 2018 Standard (s 5(1)); numerous Act-defined expressions, including ACMA, carriage service provider, carrier, Telecommunications Industry Ombudsman, network unit and telecommunications network, are noted as defined in s 7 of the Act (s 4, note).
• Provider, defined in the Direction as carriage service providers and carriers responsible for network units used in the supply of services (s 4).
• Consumer, which the Direction says has the same meaning as in the 2018 Standard (s 4).

Primary objectives the amended Standard is to achieve are set out in s 6(1): expanding the definition of “complaint” to include network outage contacts (s 6(1)(1)); ensuring prioritisation of outage-affected consumers (s 6(1)(2)); and requiring providers to have and implement complaints-handling policies and processes that are fit-for-purpose, consumer-focused, efficient, effective, professional, transparent, have appropriate internal escalation and alert consumers to external dispute resolution avenues (s 6(1)(3)(a)-(e)).

The instrument lists substantive content areas that the amended Standard may address (s 6(2)). Those include requirements for:

• user-friendly complaints policies and processes, availability and display of those policies, accessibility for all consumers and proactive provision of information about complaints handling and external dispute resolution (s 6(2)(1)(a)-(d));
• resolution of complaints in a manner commensurate with keeping consumers connected to an essential service (s 6(2)(2));
• policies and processes that prioritise quick resolution, minimise waiting time and call transfers and decrease the number of times consumers must deal with different people, and that keep consumers updated and informed about progress and resolution (s 6(2)(3)(a)-(c));
• any other matters ACMA considers necessary to give effect to the objectives (s 6(2)(4)).

The Direction grants the ACMA broad drafting discretion. ACMA may vary the 2018 Standard over time, must ensure any variations comply with the Direction (s 5(3)), may define any terms required (s 6(3)), may deal differently with different classes of providers or consumers and may exempt classes of providers from particular provisions (s 5(4); s 5(4)(a)-(c)). The Standard may also confer functions and powers on the TIO to meet the objectives (s 6(4)).

Several cross-cutting conceptual features follow from the instrument’s text. First, the Direction prescribes objectives more than technical rules; ACMA must convert those objectives into detailed regulatory obligations. Second, the Direction targets operational aspects of customer service and complaint management , accessibility, display, timeliness, escalation, communication , rather than, for example, billing practices or network engineering standards (s 6). Third, the Direction connects complaints handling to network outages and preserving connection to an “essential service”, which places an operational priority on continuity of service in the complaints-handling regime (s 6(1)(1); s 6(2)(2)). Fourth, the Direction contemplates graded regulatory treatment by class of provider or consumer, and exemptions, creating an in-built capacity for differential regulatory burden (s 5(4)).

Finally, the instrument does not itself specify enforcement mechanisms, penalties, or the content of any functions or powers to be given to the TIO; those will be specified by ACMA in the amendments to the 2018 Standard (see s 5 and s 6(4)). The Direction therefore reconfigures the scope of the 2018 Standard and channels ACMA’s regulatory discretion, but leaves the detailed mechanics to the regulator.

The Direction names two primary categories of regulated entities as “providers”: carriage service providers and carriers responsible for network units used in the supply of services by carriage service providers (s 4). That definition means that both retail-facing CSPs and carriers that operate network infrastructure used by CSPs are within the class of entities the amended Standard can require to comply. The instrument also notes that a number of expressions are defined in s 7 of the Act, including carriage service provider, carrier, network unit and telecommunications network; for precise scope of those terms the relevant Act provisions and the 2018 Standard must be consulted (s 4, note).

Consumers are affected because the Direction requires the amended Standard to treat complaints from consumers who contact providers about network outages as “complaints” (s 6(1)(1)). The Direction further requires that providers prioritise complaints from consumers affected by network outages (s 6(1)(2)). The instrument states that the word “consumer” has the same meaning as in the 2018 Standard (s 4); therefore the practical reach of consumer protections depends on the 2018 Standard’s existing definition.

The Telecommunications Industry Ombudsman (TIO) is implicated. The Direction expressly permits the amended Standard to confer functions and powers on the TIO to meet the objectives (s 6(4)). That means the TIO may be given additional regulatory or dispute-resolution roles under the Standard amendments, subject to ACMA’s drafting choices.

Third parties and intermediaries who operate call centres, outsourced complaints handling, or software used to manage complaints will be affected indirectly because the Direction sets expectations for provider policies and processes to be user-friendly, accessible and to minimise waiting times and transfers (s 6(2)(1); s 6(2)(3)). Providers typically must adapt outsourcing arrangements, contractual terms, and performance management to meet regulatory expectations; the Direction’s content implies these operational adjustments may be required.

Regulatory bodies and enforcement actors will be affected through the grant of powers and functions to the TIO and through ACMA’s continuing regulatory role. The ACMA is directed to make the amendments and may vary the Standard over time as it considers necessary (s 5(1); s 5(3)). The Direction therefore imposes workstreams on ACMA, including drafting, consultation, and implementation oversight. The TIO may receive new functions or powers under the Standard amendments (s 6(4)), which could affect its case load, resources and procedures.

Finally, some providers may be treated differently or be exempted, because the Direction allows the amended Standard to deal with matters differently for different classes of providers or to exempt certain classes from particular provisions (s 5(4)). That creates a mechanism through which smaller providers, specialist carriers, or other defined classes could face lower or different regulatory obligations, depending on how ACMA exercises that discretion.

In summary, the Direction primarily affects carriage service providers and carriers with network units in service, consumers (as defined in the 2018 Standard), the TIO, ACMA, and third-party complaint handling vendors, with scope for differentiated burdens across classes via ACMA discretion (s 4; s 5(4); s 6).

This Direction itself does not impose direct civil duties on providers; instead it requires ACMA to amend the 2018 Standard to give effect to specified objectives and content, and those amendments will create the enforceable duties. Nevertheless, the instrument identifies the substantive duties ACMA may require of providers, and indicates rights consumers must receive under the amended Standard.

Duties ACMA may impose through the amended 2018 Standard:

• Duty to treat outage contacts as complaints. The amended Standard is to ensure the definition of “complaint” appropriately includes consumers who contact a provider in relation to a network outage (s 6(1)(1)). This will obligate providers to accept such contacts as formal complaints under their complaints-handling framework, subject to the detailed wording ACMA prescribes.
• Duty to prioritise outage-affected consumers. Providers are to appropriately prioritise complaints from consumers affected by network outages (s 6(1)(2)), which will require triage and prioritisation rules in providers’ processes.
• Duty to maintain fit-for-purpose complaints-handling policies and processes. The Standard must ensure providers have and implement complaints-handling policies that are fit-for-purpose, consumer-focused, efficient, effective and professional, transparent, include internal escalation processes, and ensure consumers are provided clear information about external dispute resolution avenues at appropriate times (s 6(1)(3)(a)-(e)).
• Duties related to accessibility and communication. The amended Standard may require user-friendly policies and processes for making complaints, requirements about availability and display of those policies, accessibility for all consumers, and proactive information provision about complaints handling and external dispute resolution (s 6(2)(1)(a)-(d)).
• Duties to resolve complaints commensurate with keeping consumers connected. The Standard may require resolution of complaints in a manner commensurate with keeping consumers connected to an “essential service” (s 6(2)(2)).
• Operational duties to reduce friction. The Standard may require providers to prioritise quick resolution, minimise waiting times, minimise call transfers and repeated handoffs, and to keep consumers informed about progress and resolution (s 6(2)(3)(a)-(c)).

Rights for consumers under the amended Standard:

• Right to have outage-related contacts treated as complaints. By requiring the definition of “complaint” to include outage contacts, the Direction creates an expectation that consumers who call about outages will have their matter recognised within formal complaints channels (s 6(1)(1)).
• Right to prioritised handling where affected by outages. Consumers affected by outages are to be prioritised (s 6(1)(2)).
• Right to clear information about external dispute resolution avenues. Providers must ensure consumers are informed, at appropriate times, of avenues for external dispute resolution (s 6(1)(3)(e); s 6(2)(1)(d)).
• Rights to accessibility and user-friendly processes. The amended Standard may enshrine rights to accessible and clearly displayed complaints processes and proactive information (s 6(2)(1)).

Discretion and delegation:

• The direction gives ACMA discretion to define terms and to deal differently with classes of providers or consumers, and to grant exemptions (s 5(3)-(4); s 6(3)). ACMA’s choice will determine the final shape and scope of duties.
• The Standard may confer functions and powers on the TIO (s 6(4)), which could effectively create rights of access to external dispute resolution or procedural rights before the TIO depending on what ACMA prescribes.

Limitations and omissions in the instrument:

• The Direction itself does not set enforcement mechanisms, sanctions, or specific remedies. It instructs ACMA to amend the 2018 Standard but does not specify penalties in the text provided (see s 5-6). Any penalties or enforceable compliance measures will depend on the content ACMA adopts.
• The Direction refers to “essential service” in framing resolution obligations (s 6(2)(2)) but does not define that term within the instrument; ACMA may define it under s 6(3).

In short, the instrument prescribes a set of objectives and potential content that will translate into duties and rights once ACMA issues the amended 2018 Standard. The practical scope of duties and consumer rights will depend on ACMA’s drafting, including use of the Direction’s permissive power to differentiate by class or to confer functions on the TIO (s 5(4); s 6(3)-(4)).

The Direction does not itself create explicit penalties, fines, or enforcement processes in the text provided. The mechanism it uses is to direct ACMA to amend the 2018 Standard to achieve the stated objectives (s 5(1); s 6). The instrument authorises ACMA to define terms and to confer functions and powers on the Telecommunications Industry Ombudsman in the amended Standard (s 6(3)-(4)). Any enforcement, sanctioning or compliance-measure regime therefore depends on the content ACMA inserts into the 2018 Standard.

What the instrument does specify about enforcement architecture and administrative authority:

• ACMA is the decision-maker tasked with producing the amendments and with varying the Standard over time so long as the Standard, as varied, complies with this Direction (s 5(3)). That assigns responsibility for design, implementation, monitoring and potential enforcement mechanisms to ACMA.
• The Standard may confer functions and powers on the Telecommunications Industry Ombudsman to meet the objectives (s 6(4)). That signals a route for enforcement or dispute-resolution via an external dispute resolution body, though the instrument does not itself define the exact functions or powers to be conferred.

What the instrument does not contain:

• No penalties, infringement notices, civil penalties or criminal sanctions are specified in this Direction’s text. The Direction is limited to prescribing objectives and permitted content for the Standard; it does not itself alter statutory penalty regimes in the Act nor specify new sanctions.
• No compliance reporting regimes, audit powers, inspection powers, administrative fines or enforcement timelines are set out in the instrument. Those features, if any, would need to appear in the amended 2018 Standard or in other statutory instruments or regulatory rules.

Implementation implications for enforcement:

• ACMA will need to decide, when drafting the amended Standard, whether to include enforceable obligations with associated sanctions, compliance reporting obligations, or to rely primarily on administrative enforcement and dispute-resolution through the TIO (s 6(4)).
• If ACMA confers powers on the TIO, the TIO may be given an enhanced capacity to receive complaints, mediate, adjudicate or make binding determinations, depending on the powers ACMA decides to transfer. The Direction makes clear this is within ACMA’s drafting scope but does not prescribe the content (s 6(4)).
• The Direction’s allowance for exemptions and differing treatment of classes of providers (s 5(4)) could create a varied enforcement landscape where some providers are subject to stricter obligations and enforcement than others.

For practitioners, the absence of explicit penalties in the Direction means a close reading of the amended 2018 Standard, once made by ACMA, will be necessary to identify enforceable obligations, compliance requirements and any sanctioning mechanisms. The Direction binds ACMA’s drafting parameters and timeline (s 5(2)), but enforcement mechanics rest with whatever ACMA prescribes.

The instrument is made under s 125AA(4) of the Telecommunications Act 1997 and explicitly operates through amendment of an existing industry Standard under that Act (s 3; s 5(1)). The Direction notes that a number of expressions used in the instrument are defined in s 7 of the Act, including ACMA, carriage service provider, carrier, Telecommunications Industry Ombudsman, network unit and telecommunications network; it also says the term “consumer” has the same meaning as in the 2018 Standard (s 4, note; s 4). This means the Direction and the amended Standard will operate within the definitional and jurisdictional framework established by the Act and the existing 2018 Standard.

The instrument does not expressly mention other Commonwealth statutes such as the Competition and Consumer Act, the Privacy Act, consumer credit laws, workplace laws or state-based consumer-protection regimes. Therefore, from the text supplied:

• The Direction is silent on how the amended Standard will interact with consumer-protection provisions in other legislation. The 2018 Standard sits within the Telecommunications Act’s regulatory architecture; any overlap or conflict with other laws would need to be assessed by reference to those other statutes and the content ACMA prescribes in the amended Standard.
• The Direction contemplates external dispute resolution through the TIO (s 6(4)). Interaction between TIO functions (as potentially expanded) and other dispute-resolution avenues remains a matter for ACMA to address in the Standard.

Relevant interaction points that arise from the instrument and will require cross-referencing when the Standard is amended:

• Definitions. The instrument relies on definitions in s 7 of the Act and the 2018 Standard (s 4). Lawyers will need to map those definitions against other legal definitions used in overlapping regimes (for example, definitions of “consumer” or “essential service”) when interpreting duties and rights created by the amended Standard.
• Essential service reference. The Direction requires resolution commensurate with keeping consumers connected to an “essential service” (s 6(2)(2)). The instrument does not define “essential service”; ACMA may define it under s 6(3). Depending on the definition ACMA adopts, there could be interaction with other legal frameworks that treat certain services as essential or critical infrastructure.
• External dispute resolution (EDR) and the TIO. The Direction allows the Standard to confer functions and powers on the TIO (s 6(4)). Any augmentation of the TIO’s role will overlap with rights under other dispute-resolution processes and possibly with statutory complaint pathways. The exact interplay will depend on ACMA’s drafting and on existing TIO rules.
• Differential treatment and exemptions. The Direction allows ACMA to treat classes differently or to grant exemptions (s 5(4)). This could create a regulatory scheme that departs from uniform application of consumer-protection rules and thereby interacts structurally with competition considerations or obligations in other laws that assume uniform regulation.

In sum, the Direction situates its amendments within the Telecommunications Act framework (s 3; s 4) and leaves the specifics of cross‑statutory interaction to ACMA’s drafting. Practitioners must therefore look to the amended 2018 Standard and the Act’s definitional provisions to assess how the new complaints-handling requirements will coexist with other regulatory, privacy and consumer-protection obligations.

This Direction is titled the Telecommunications (Complaints Handling Industry Standard Amendment) Direction 2024 and is dated 21 August 2024 (instrument name and header). It is an instrument made under subsection 125AA(4) of the Telecommunications Act 1997 (s 3). The Direction amends the scope and required objectives of the existing Telecommunications (Consumer Complaints Handling) Industry Standard 2018 (the 2018 Standard) by directing ACMA to make specific changes and by setting timeframes for those changes (s 5(1)-(2)).

The instrument provides procedural details for the amendment process:

• It requires the ACMA to determine the amendments no later than 30 April 2025 (s 5(2)(1)).
• It requires the amendments to commence in full at the earliest practical opportunity and no later than 30 June 2025 (s 5(2)(2)).
• It gives ACMA ongoing power to vary the 2018 Standard as it considers necessary from time to time, provided the standard as varied complies with the Direction (s 5(3)).
• It permits the amended Standard to treat different classes of providers or consumers differently and to exempt certain classes of providers from particular provisions (s 5(4)).

The Direction signals that the 2018 Standard itself is the subject of amendment rather than replacing it wholesale. It contemplates that the 2018 Standard, post-amendment, may include new definitions, operational requirements and delegated powers (s 6(3)-(4)). The Direction therefore functions as a legislative-level instruction to the regulator with explicit deadlines and parameters for the amendments.

The instrument does not record prior amendments to the 2018 Standard within its text. It refers to the 2018 Standard as the existing instrument to be amended (s 4). Any previous amendment history of the 2018 Standard is not reproduced in this Direction. The Direction itself constitutes a formal action in the statutory amendment process under the Act, invoking the Minister’s power to direct ACMA as provided in s 125AA.

Because the Direction authorises ACMA to vary the Standard over time provided compliance with the Direction, the 2018 Standard as amended will itself be an evolving instrument (s 5(3)). The Direction’s express allowance for different treatment by classes of providers (s 5(4)) means future amendments by ACMA may be incremental or targeted, not necessarily uniform.

Practitioners wanting a chronological record should therefore:

• Treat this Direction (21 August 2024) as a discrete amendment-making instruction and timeline for ACMA.
• Expect ACMA to publish the amended 2018 Standard by the determination deadline (by 30 April 2025), and for the amendments to be in force no later than 30 June 2025 (s 5(2)).
• Note the ongoing capacity for ACMA to vary the Standard after initial amendment, subject to the boundaries of this Direction (s 5(3)).

Any prior amendments or future variations to the 2018 Standard outside the confines of this Direction would need to be found by consulting the 2018 Standard’s instrument history and subsequent ACMA publications; the Direction itself supplies the single dated instruction and framework included here.

The Direction text supplied contains no reference to litigation, judicial review, or any court or tribunal decisions. It is a ministerial direction made under s 125AA(4) of the Telecommunications Act 1997 and sets parameters for ACMA to amend the 2018 Standard (s 3; s 5). The instrument does not record any legal challenges to the Direction, to the 2018 Standard, or to the ACMA’s exercise of powers. It also does not identify any existing litigation concerning the 2018 Standard or complaints-handling regimes.

Because the Direction authorises ACMA to amend the 2018 Standard, potential litigation could occur around:

• the exercise of ACMA’s discretion in defining terms or conferring powers on the TIO, if stakeholders challenge those decisions after the Standard is amended (s 6(3)-(4));
• the imposition of particular obligations or exemptions for classes of providers, particularly if affected providers argue procedural unfairness or jurisdictional error in ACMA’s exercise of its powers (s 5(4));
• any enforcement actions taken under the amended Standard, depending on the enforcement and penalty mechanisms ACMA inserts into the Standard.

However, none of these potentialities is recorded in this instrument. To identify actual litigation history practitioners must review case law databases and any judicial review filings made after the publication of the Direction or after ACMA’s amendment of the 2018 Standard. The Direction supplies no factual or legal narrative of past or pending litigation. It simply instructs ACMA to act within the timeline and scope described.

In short, the instrument contains no litigation history. Any legal proceedings that may arise from the amended Standard will be matters external to the Direction and must be tracked via court records and ACMA or TIO publications once the Standard is amended and operational.

Several features of the Direction that can produce compliance surprises or interpretation issues are evident from the instrument’s text.

1. The Direction mandates objectives, not granular rules. The instrument sets the policy objectives the amended Standard must give effect to (s 6(1)) and lists matters that the amended Standard may include (s 6(2)), but it leaves detailed drafting to ACMA. That means providers cannot rely on the Direction alone to know the specific operational obligations they will face; they must wait for ACMA’s amended Standard. Until ACMA publishes the detailed requirements, there is uncertainty about the precise legal duties, metrics, reporting obligations and any sanctions.

2.wide drafting discretion for ACMA. ACMA may define terms as it considers appropriate (s 6(3)), and may vary the 2018 Standard from time to time as long as variations comply with the Direction (s 5(3)). The potential for varied definitions and ongoing amendments introduces regulatory uncertainty for providers who will need to track ACMA’s future variations and any redefinitions that can materially change obligations.

3. Differential treatment and exemptions. The Direction permits the amended Standard to treat different classes of providers or consumers differently and to exempt classes of providers from particular provisions (s 5(4)). Practitioners should not assume uniform application; instead, ACMA may create multiple compliance tiers. That can present strategic issues for both providers who might seek exemption and for those who will remain subject to stricter obligations.

4. Broad operational expectations are specified. The Direction contemplates requirements to make policies user-friendly, to display them, to ensure accessibility, to minimise waiting times and call transfers, to prioritise outage-affected consumers, and to keep consumers updated (s 6(2)(1)-(3)). These expectations span organisational policy, front-line processes, customer-communications systems and IT. Providers that outsource complaints handling or use multiple vendors will need to revisit contractual terms, SLAs and systems to ensure alignment.

5. “Complaint” scope change. The Direction requires that the definition of “complaint” appropriately include consumers who contact a provider in relation to a network outage (s 6(1)(1)). The 2018 Standard itself contains the operative definition of “consumer” and the existing complaint framework; providers must consult the amended Standard and the 2018 Standard to understand how outage contacts will be classified, triaged and counted. Expect operational accounting and reporting implications if outage contacts are formally reclassified as complaints.

6. “Essential service” phrase is undefined in the Direction. The Direction requires complaint resolution commensurate with keeping consumers connected to an “essential service” (s 6(2)(2)) but does not define that term. ACMA may define it, but until it does providers will face ambiguity about the threshold and the practical steps required to achieve “commensurate” resolution.

7. External dispute resolution implications. The Direction allows the Standard to confer functions and powers on the TIO (s 6(4)). Depending on what powers are conferred, providers may see increased escalation to the TIO, different dispute-resolution timelines or binding determinations. Until the Standard is finalised, the practical consequences for providers’ exposure to EDR are uncertain.

8. Tight timeframes. The Direction requires ACMA to determine amendments by 30 April 2025 and for amendments to commence no later than 30 June 2025 (s 5(2)). That compresses the regulatory timeline for ACMA and stakeholders, potentially limiting the time for consultation and for providers to change systems and training.

9. No enforcement detail in the Direction. The instrument does not set penalties or enforcement mechanisms (s 5-6). Providers should not assume that the absence of penalties in the Direction means the amended Standard will lack enforcement mechanisms; ACMA could include sanctions, monitoring or reporting obligations. Conversely, the absence of explicit sanctions in the Direction could mean ACMA relies mainly on the TIO, non‑binding expectations or administrative enforcement.

10. Definition reliance on external instruments. “Consumer” is defined in the 2018 Standard; other key terms are defined in the Act (s 4). Providers need to trace definitions across instruments; misreading where a definition is located could produce compliance gaps.

Each of these items is grounded in the Direction’s text. The practical upshot for affected parties is that the regulatory obligation is real and time-bound, but the detailed legal and operational implications will flow from ACMA’s drafting choices and any functions and powers the amended Standard confers on the TIO.

The Direction requires ACMA to draft amendments, but it prescribes the substantive outcomes the amendments must achieve (s 6). Providers should therefore act now to prepare for the likely content and timing of the amended 2018 Standard. The following checklist is a practical, source‑grounded compliance roadmap derived from the Direction’s objectives and permitted content (s 6(1)-(2)). The list assumes ACMA will adopt obligations consistent with the Direction’s enumerated matters.

1. Legal and governance preparation

• Identify the internal owner responsible for regulatory change (e.g., Head of Compliance or Regulatory Affairs) and a cross-functional steering group (customer operations, networks, legal, IT, vendor management).
• Map whether your organisation is captured as a “provider” under the Direction (carriage service provider or a carrier responsible for network units used to supply services) and identify any carrier partners whose network units are used in your supply chain (s 4).
• Track ACMA’s amendment timetable: determination by 30 April 2025; commencement no later than 30 June 2025 (s 5(2)).

2. Review and update complaints definitions and triage

• Prepare to revise internal definitions and call-centre scripts so that consumer contacts about network outages are captured as formal complaints per the Direction’s objective to include outage contacts within the “complaint” definition (s 6(1)(1)).
• Design triage protocols to prioritise outage-affected consumers consistent with s 6(1)(2) and s 6(2)(3)(a) (prioritise resolving complaints quickly).

3. Policies, processes and accessibility

• Audit existing complaints policies against the Direction’s expectations: fit-for-purpose, consumer-focused, efficient, effective and professional, transparent, with internal escalation and information on external dispute resolution (s 6(1)(3)(a)-(e)).
• Ensure policies are user-friendly and publicly available and displayed where required , the Direction contemplates requirements for availability and display (s 6(2)(1)(a)-(b)).
• Confirm accessibility for all consumers, including reasonable adjustments, alternative formats and multilingual support as necessary (s 6(2)(1)(c)).

4. Operational changes to reduce friction

• Reconfigure workforce and vendor processes to minimise waiting times, reduce call transfers and minimise the number of different people a consumer must engage with, as urged in s 6(2)(3)(b).
• Implement single‑case ownership or clearly defined escalation pathways to satisfy internal escalation requirements (s 6(1)(3)(d)) and to reduce repeated handoffs.

5. Communications and customer updates

• Put in place automated and manual customer‑update mechanisms to keep consumers informed about complaint progress and resolution (s 6(2)(3)(c)).
• Develop proactive information materials and online content about complaints handling and external dispute resolution options, anticipating s 6(2)(1)(d).

6. Outage-specific procedures

• Establish outage detection and customer-notification linkages between network operations and customer services so that when an outage is identified, affected consumers are identified and complaints are flagged for prioritised handling (s 6(1)(2); s 6(2)(2)).
• Document procedures for complaint resolution that are “commensurate with keeping consumers connected to an essential service” (s 6(2)(2)). Consider fallback connectivity options and rapid escalation to network units/carriers where appropriate.

7. External Dispute Resolution and the TIO

• Review contracts and EDR obligations in light of the Direction’s permission for ACMA to confer functions and powers on the TIO (s 6(4)). Plan for potential changes in escalation patterns to the TIO and ensure records and case files are EDR-ready.

8. Systems, data and reporting readiness

• Prepare IT changes to allow tracking of outage-related complaints as complaints, prioritisation flags, waiting times, transfer counts and customer update logs, reflecting the operational metrics implicit in s 6(2)(3).
• Anticipate reporting requirements ACMA may impose; set up internal dashboards to capture response times, escalation rates, accessibility accommodations and EDR notifications.

9. Contracting and vendor management

• Update service-level agreements (SLAs) with call centres, third-party service providers and network carriers to reflect the need for quicker resolution, fewer transfers, prioritised handling and accessible procedures (s 6(2)(3); s 6(2)(1)).
• If you are a carrier responsible for network units, ensure contractual terms with retail CSPs reflect the obligations the amended Standard may impose (s 4).

10. Training and culture

• Train front-line staff to recognise outage-related contacts as complaints eligible for prioritisation, to minimise transfers, and to communicate clearly about EDR options (s 6(1)(1)-(3); s 6(2)(1)-(3)).
• Embed escalation protocols into training so that internal escalation obligations in s 6(1)(3)(d) are executed promptly.

11. Legal review and risk assessment

• Obtain legal advice on how ACMA may exercise the Direction’s powers, including possible definitions of “essential service”, class-based exemptions and conferral of functions to the TIO (s 5(4); s 6(3)-(4)).
• Assess risk of differing regulatory obligations across classes of providers if exemptions or differential treatment are implemented (s 5(4)).

12. Stakeholder engagement

• Engage with ACMA consultations and provide evidence on operational feasibility, costs, and timelines, given ACMA’s power to define terms and vary the Standard (s 6(3); s 5(3)).
• Coordinate with carriers and industry bodies to align outage notification and complaint handling processes across parties.

Timeline summary based on the Direction:

• Immediate: governance, mapping and scoping work; vendor and contract review.
• Before ACMA’s determination (by 30 April 2025): be prepared to respond to consultation drafts; model system changes and budget for implementation.
• Implementation window (up to 30 June 2025): deploy system changes, staff training and policy updates to align with the amended Standard as published by ACMA (s 5(2)).

This roadmap is grounded in the Direction’s specified objectives and permitted content (s 6). Because the Direction leaves detail to ACMA, prudent providers should prepare for a range of possible obligations, engage with ACMA’s process, and prioritise changes that give effect to the Direction’s core goals: capture outage contacts as complaints, prioritise outage-affected consumers, reduce friction in complaint handling and ensure transparent access to external dispute resolution (s 6(1)-(2)).