Telecommunications (Mobile Network Coverage Maps) Direction 2025

The instrument uses a small set of central concepts, and it constrains ACMA’s mandate to produce a standard that implements those concepts.

Relevant Mobile Telecommunications Service

• The direction defines Relevant Mobile Telecommunications Service in detail (s 4). The core features are: (a) the service is not Wi‑Fi; (b) the end‑user can use the carriage service while moving continuously between places; (c) the customer equipment is not in physical contact with the telecommunications network and is not a smart device (the text gives a smart watch as an example); (d) the service enables voice calls or SMS, or data/internet access; and (e) the service is supplied to the public (s 4, definition).
• The definition therefore focuses the standard on mobile, public-facing services delivered to untethered devices (not Wi‑Fi, not devices physically connected to the network, and not smart devices).

Standard and ACMA’s role

• The Minister directs ACMA to determine a standard under s 125AA(1) of the Act (s 5(1)). The direction fixes timing milestones for determination and commencement (s 5(2)(a)-(b)) and allows ACMA to vary the standard provided the variations comply with the direction (s 5(3)). ACMA may also define terms necessary to implement the standard (s 5(4)).

Scope and differentiation

• The standard is to apply, as relevant, to carriers and carriage service providers who supply Relevant Mobile Telecommunications Services (s 6(1)). The standard may treat different classes of carriers or providers differently and may exempt certain classes from particular provisions (s 6(2)(a)-(b)). This creates an explicit power to calibrate requirements according to provider class or service type.

Objectives the standard must give effect to

• The direction lists specific objectives the standard must give effect to about how carriers and providers represent network coverage (s 7(1)). These objectives include comparability of maps (s 7(1)(a)), clear, up‑to‑date and useful information with methodologies and assumptions that reflect on‑ground experience (s 7(1)(b)(i)-(v)), standardised service metrics (s 7(1)(b)(ii)), plain‑language visual representations linked to indicative end‑user activities (s 7(1)(b)(iii)-(iv)), compliance with Web Content Accessibility Guidelines 2.2 or replacements (s 7(1)(b)(iv)), transparency about limitations such as indoor coverage or coverage in moving vehicles (s 7(1)(b)(v)), capability to enable extraction of map data for analytical use by other organisations (s 7(1)(b)(vi)), and capture of multiple network technologies including Low Earth Orbit satellite direct‑to‑device platforms (s 7(1)(b)(vii) and s 7(1)(c)).

Interaction with the National Audit

• In preparing the standard ACMA must have regard to all available findings of the National Audit of Mobile Coverage (s 7(2)). The direction also defines the National Audit as the Australian Government initiative conducted by Accenture Australia that independently measures and maps real‑world mobile phone coverage across regional and rural Australia (s 4).

Definitions and cross‑references

• The instrument notes that a number of expressions used in the instrument are defined in section 7 of the Act, including ACMA, carrier, carriage service, carriage service provider, customer equipment, and telecommunications network (s 4 note). ACMA is also authorised to define further terms as necessary to determine the standard (s 5(4)).

These concepts structure the forthcoming standard: ACMA will translate these objectives and definitions into technical specifications, data formats, accessibility requirements and any compliance regime that will apply to carriers and carriage service providers supplying Relevant Mobile Telecommunications Services.

The instrument frames its regulatory target as carriers and carriage service providers who supply Relevant Mobile Telecommunications Services (s 6(1)). The instrument’s definition of Relevant Mobile Telecommunications Service narrows that target in several concrete ways (s 4).

Immediate addressees

• Carriers and carriage service providers who supply services meeting the definition of Relevant Mobile Telecommunications Service will be in scope of the standard once ACMA determines it (s 6(1)). The direction does not itself impose obligations directly on carriers and providers; rather it requires ACMA to make a standard that will apply to them (s 5(1)).

Services included and excluded

• Included services must be publicly supplied, usable while the end‑user is moving continuously between places, and provide voice/SMS or data/internet access (s 4). Excluded services include Wi‑Fi services (“other than a wi‑fi service” in the definition) and connections where customer equipment is in physical contact with the telecommunications network (s 4). The definition also excludes “smart devices” (for example smart watches), so services that are specifically targeted to or delivered to smart devices as defined may fall outside the standard’s scope (s 4).

Geography and user type

• The instrument does not itself restrict the standard to particular geographic areas; the National Audit of Mobile Coverage is focused on regional and rural Australia (s 4 definition of National Audit), and ACMA must have regard to the Audit’s findings (s 7(2)), but the direction’s language about “a given geographical area” in relation to the information required (s 7(1)(b)) is general rather than territorially limited. The standard can therefore be crafted to apply across Australia or to specified areas, subject to ACMA’s exercise of its drafting discretion and the direction’s allowance for class‑based differentiation or exemptions (s 6(2)).

Organisations and third‑party users

• The standard must enable extraction of published mobile coverage map data by other organisations (for example emergency services organisations) for analytical purposes (s 7(1)(b)(vi)). This imposes an obligation on carriers/providers, through the standard, to publish data in an extractable form useful to third parties.

ACMA and the Minister

• The Minister decides the policy objective by issuing the direction and the timetable (s 5), while ACMA is the deciding administrative agency required to convert the direction into a standard. ACMA has discretion to define terms and vary the standard over time subject to compliance with the direction (s 5(3)-(4)).

Potentially affected classes and carve‑outs

• The direction explicitly contemplates that ACMA may treat different classes of carriers and carriage service providers differently or exempt particular classes from parts of the standard (s 6(2)). This creates scope for differential treatment based on provider size, technology, service type, or other categorisations ACMA adopts when drafting the standard.

In short, the instrument places carriers and carriage service providers supplying public, mobile, untethered voice/SMS or data services in scope, while excluding Wi‑Fi and certain device types; the exact boundary and differential treatment will be set by ACMA in the standard it is directed to make.

The direction itself sets objectives and boundaries rather than immediate legal duties on carriers and carriage service providers; the duties will be created by the ACMA standard that the Minister directs ACMA to make. Still, the direction prescribes what that standard must require and therefore sketches the substantive duties ACMA is instructed to impose.

Duties to be imposed via the standard

• ACMA is directed to determine a standard that gives effect to the objectives in section 7, and those objectives specify the content and form of how network coverage is represented to the public (s 5(1); s 7(1)). The standard therefore must require (or at least enable) carriers/providers to prepare and publish mobile coverage maps that are comparable, clear, up‑to‑date and useful (s 7(1)(a)-(b)).

Specific elements the standard must give effect to (and thus may translate into duties)

• Standardisation and comparability: maps must be prepared and published in a manner that is comparable; the standard must standardise approaches to the extent necessary to ensure meaningful comparability (s 7(1)(a)).
• Methodology, assumptions and realism: maps should incorporate appropriate modelling methodologies and assumptions so there is a reasonable likelihood they represent on‑ground experience (s 7(1)(b)(i)).
• Service metrics: the standard must require a standardised approach to service metrics, such as signal strength, reliability and quality (s 7(1)(b)(ii)).
• Visual and plain‑language representation: the standard must include visual representation of expected service levels with plain language descriptions of indicative end‑user activities at each level (s 7(1)(b)(iii)-(iv)).
• Accessibility: the standard must require compliance with WCAG 2.2 or replacement accessibility guidelines (s 7(1)(b)(iv)).
• Transparency about limitations: maps must provide information explaining methodologies, assumptions and limitations around accuracy , for example indoor coverage, coverage in moving vehicles, congested areas and known blackspots that may conflict with predicted coverage (s 7(1)(b)(v)).
• Data extractability: carriers/providers must publish maps in a way that enables data to be extracted by other organisations for analytical purposes (s 7(1)(b)(vi)).
• Technology coverage: maps must capture information required for different network technologies or platforms used to supply Relevant Mobile Telecommunications Services, for example Low Earth Orbit satellite Direct to Device (s 7(1)(b)(vii) and s 7(1)(c)).

Discretion and class treatment

• The standard may treat different classes of carriers or providers differently and may exempt classes from particular provisions (s 6(2)). That discretion is an explicit right to differential regulatory treatment that ACMA must use when drafting compliance obligations.

Transparency and procedural rights

• ACMA is authorised to define terms necessary to implement the standard (s 5(4)), and must have regard to the National Audit’s findings (s 7(2)). The direction does not specify consultation requirements or appeals mechanisms for regulated entities; any procedural rights (such as consultation, transitional arrangements, or review mechanisms) will depend on the content of the standard ACMA produces and the procedural rules in the Telecommunications Act and ACMA’s regulatory processes.

Absence of explicit enforcement or penalty regime in the direction

• The direction itself does not specify penalties, sanctions, or compliance enforcement measures (no provision in the instrument prescribes these). Enforcement and sanctions, if any, will depend on the content of the standard ACMA determines and any enforcement powers the Act provides to ACMA. The direction merely requires ACMA to implement the objectives through a standard (s 5(1); s 7).

In sum, the key duties will be those ACMA imposes under the standard; the direction circumscribes those duties by mandating specific content areas , comparability, methodology, accessibility, transparency and data extractability , and gives ACMA limited discretion to differentiate obligations by class or to exempt classes (s 6(2)).

The direction does not itself set out a penalty or enforcement framework. It is a ministerial instruction to ACMA to make a standard under subsection 125AA(1) of the Telecommunications Act 1997, and it sets objectives and timing but does not prescribe sanctions or compliance remedies within the text of the direction (s 3; s 5(1)). The following points summarise what the instrument says, and what it leaves to ACMA or the Act.

No penalties in the instrument

• There is no provision in the direction that imposes fines, civil penalties, criminal sanctions, or specific administrative enforcement measures on carriers or carriage service providers in this instrument itself. The legal effect of the direction is to require ACMA to make a standard that gives effect to the objectives listed (s 5(1); s 7).

Enforcement will depend on the ACMA standard and the Act

• Because the direction directs ACMA to make a standard under s 125AA(1) of the Act (s 5(1)), any enforceable obligations, compliance mechanisms, monitoring arrangements and penalty provisions would need to be contained in the standard ACMA determines, and/or derive from ACMA’s enforcement powers under the Telecommunications Act. This instrument does not define or limit those powers; it only prescribes content and deadlines for the standard.

ACMA’s power to vary the standard

• The Minister expressly permits ACMA to vary the standard as necessary from time to time provided the standard as varied complies with the timing and application conditions in the direction (s 5(3)). Variations could include adding or amending compliance or enforcement provisions, subject to the constraints of the Act and the direction’s requirements, but the instrument itself does not mandate any particular enforcement approach.

Implication for regulated entities

• Because the direction does not set penalties, regulated entities cannot look to this instrument alone for certainty about enforcement risk. They will need to monitor the standard ACMA publishes (and any subsequent variations) for the specific compliance, monitoring and sanction regimes.

Transparency and accountability features that affect enforcement design

• The direction requires the standard to include transparency obligations , e.g. explanations of methodologies, assumptions and limitations (s 7(1)(b)(v)) , and the capability for enabling extraction of map data by other organisations (s 7(1)(b)(vi)). These transparency features, once implemented by the standard, will create external information flows that third parties (including emergency services and potentially regulators) can use to check compliance. The instrument does not state how ACMA will use that information for enforcement.

In short, the direction mandates content and deadlines for a mapping standard, but it leaves the penalties and enforcement architecture to ACMA’s standard and the Telecommunications Act. Regulated entities should therefore assume that enforcement details and practical compliance obligations will appear in the forthcoming ACMA instrument rather than in the Ministerial direction itself.

The direction explicitly situates itself within the framework of the Telecommunications Act 1997 and references non‑statutory standards and government audit work. The instrument relies on, and cross‑refers to, definitions and initiatives external to the instrument; those linkages determine interaction points with other legal and policy instruments.

Telecommunications Act 1997

• The direction is made under subsection 125AA(4) of the Telecommunications Act 1997 and directs ACMA to determine a standard under subsection 125AA(1) of the Act (s 3; s 5(1)). The instrument therefore operates by delegating to ACMA powers conferred by the Act. The instrument also notes that a number of expressions used in the instrument are defined in section 7 of the Act , including ACMA, carrier, carriage service, carriage service provider, customer equipment and telecommunications network (s 4 note). Those Act definitions will determine the meaning of key terms in the standard unless ACMA defines terms differently pursuant to the direction’s authorisation (s 5(4)).

Web Content Accessibility Guidelines and accessibility obligations

• The direction requires that mobile coverage maps be prepared and published in a manner that complies with Web Content Accessibility Guidelines (WCAG) 2.2, any replacement guidelines or other best practice regarding accessibility (s 7(1)(b)(iv)). WCAG 2.2 is an external technical standard (non‑statutory). Compliance with WCAG could interact with the Disability Discrimination Act or other accessibility obligations, depending on how the standard is drafted, but the instrument itself only mandates adherence to WCAG 2.2 or replacement guidelines; it does not assert or amend any other statutory duties.

National Audit of Mobile Coverage

• The instrument defines the National Audit of Mobile Coverage as the Australian Government initiative, conducted by Accenture Australia, which independently measures and maps real‑world mobile coverage across regional and rural Australia (s 4). ACMA must have regard to all available findings of that Audit when developing the standard (s 7(2)). Thus the standard must be informed by an existing government audit exercise, and the Audit’s findings are an evidentiary input ACMA must consider.

Data sharing and other regulatory regimes

• The direction requires capability for enabling data contained in published mobile coverage maps to be extracted by other organisations for analytical purposes (s 7(1)(b)(vi)). That requirement may interact with laws governing data access, privacy, confidentiality or national security when ACMA designs the format, scope and access controls for extractable datasets. The instrument does not itself address data protection or privacy requirements; ACMA would need to reconcile any extractability requirements with applicable data protection or sectoral legal constraints when drafting the standard.

Technology‑neutral references and sectoral regimes

• The direction requires that maps capture information for different network technologies and platforms, including Low Earth Orbit satellite Direct to Device services (s 7(1)(b)(vii); s 7(1)(c)). Provisioning and regulation of satellite services may intersect with other legislative or regulatory instruments dealing with spectrum, space activities, or radio communications. The direction does not supersede those regimes; it only requires the mapping standard to reflect multiple technologies used to provide Relevant Mobile Telecommunications Services.

Administrative law and procedural fairness

• The Minister’s direction delegates to ACMA the task of making the standard and permits ACMA to define further terms and vary the standard (s 5(3)-(4)). ACMA’s exercise of those powers will be subject to the usual administrative law constraints that apply to statutory decision‑makers, although the instrument itself does not detail consultation or procedural requirements. ACMA’s processes for consultation, regulatory impact assessment and publication will therefore govern the practical interaction between this direction and broader administrative law obligations.

In summary, the direction interfaces directly with the Telecommunications Act 1997, incorporates an external audit as an evidentiary input, requires adherence to accessibility guidance (WCAG 2.2), and raises structural interactions with data, spectrum and other sector‑specific laws which ACMA will need to consider when drafting the standard. The instrument itself does not resolve conflicts; it channels ACMA to make a standard consistent with the Act and with the enumerated objectives.

This instrument contains its own internal structure identifying commencement, authority and dates for ACMA to act. The body of the instrument records the making authority and an apparent date stamp, but it does not record prior amendments or a legislative history beyond the date it was made.

Recorded dates and commencement

• The instrument is dated 8 December 2025 and is signed by Anika Wells, Minister for Communications (heading and preamble). Section 2 states that the instrument commences the day after this instrument is registered (s 2). The instrument directs timelines for ACMA to determine and commence the standard: determination no later than 31 March 2026 and commencement in full at the earliest opportunity and by no later than 30 June 2026 (s 5(2)(a)-(b)).

No amendments listed

• The text of the instrument does not include a schedule of prior amendments or indications that it replaces an earlier direction. There is no provision in the instrument that records amendments, transitional provisions from earlier standards, or a saving clause. Accordingly, the instrument as presented does not include an amendment history.

ACMA’s ability to vary the standard

• The instrument does permit ACMA to vary the standard as it considers necessary from time to time provided that the standard as varied complies with subsection 5(1) and section 6 of the instrument (s 5(3)). That authorises future changes to the standard’s substantive requirements, but it does not constitute an amendment to the direction itself. The Ministerial direction remains the controlling policy instruction unless and until it is replaced or revoked through the processes available under the Telecommunications Act or by subsequent ministerial directions.

Practical consequence for tracking changes

• Because the instrument grants ACMA permission to vary the standard, stakeholders will need to track the ACMA standard and its variations for the operative regulatory requirements over time, not just the Ministerial direction. The instrument itself sets the framework and the limits of ACMA’s variation power (s 5(3)); however, the amendment history of the concrete obligations will principally be in the ACMA standard and its published variations.

In short, this instrument does not itself show any amendments; it sets commencement mechanics and deadlines, and it authorises ACMA to vary the standard in future, which is where the substantive amendment history of the obligations will likely arise.

The instrument contains no record of litigation. It does not reference any judicial decisions, court challenges, or precedent bearing on its content. The printed text makes no mention of existing or pending litigation involving the direction, ACMA’s responsibilities under it, the National Audit, or the carriers and carriage service providers who will be affected.

What the absence means

• The lack of litigation history in the instrument itself simply reflects that the direction is a policy instrument; it does not provide any indication of whether the ACMA standard that follows will be litigated. The instrument’s legal basis is subsection 125AA(4) of the Telecommunications Act 1997 (s 3); the potential for legal challenges will depend on the content of the standard ACMA determines and the procedures ACMA follows in making or varying that standard. Any future litigation risk would arise from challenges to the ACMA standard, procedural complaints about consultation or administrative process, or disputes about the interpretation and application of the standard to particular carriers or services.

Monitoring for future cases

• Stakeholders should monitor ACMA’s standard, any consultation documents, and subsequent enforcement actions for potential legal disputes. Because the instrument requires ACMA to have regard to findings of the National Audit (s 7(2)) and gives ACMA discretion to define terms (s 5(4)) and to treat classes differently or exempt classes (s 6(2)), disagreements about the exercise of that discretion and the substantive obligations ACMA imposes are plausible loci for future litigation, but none is recorded in the instrument itself.

In sum, there is no litigation history recorded in the instrument; any litigation will flow from ACMA’s implementation of the direction, the procedural steps ACMA takes, and the content of the standard.

The instrument is short, but it contains several features and drafting choices that create practical risks, deadlines, and areas where regulated parties need to pay attention when ACMA drafts the standard.

Timing pressure and staged deadlines

• ACMA is required to determine the standard by 31 March 2026 and to have it commence in full no later than 30 June 2026 (s 5(2)(a)-(b)). The instrument commences the day after registration (s 2). These fixed dates compress the timeframe for ACMA to consult, finalise technical specifications (including data formats and accessibility compliance), and set transitional arrangements. Carriers and carriage service providers should note the compressed timetable for implementation planning.

Scope definition nuances

• The direction’s definition of Relevant Mobile Telecommunications Service excludes Wi‑Fi services and services where customer equipment is in physical contact with the telecommunications network, and it excludes smart devices (s 4). Operators whose offerings sit near those boundaries , for example fixed wireless services, proprietary in‑vehicle systems, tethered device services, or smart device ecosystems , will need to evaluate whether the standard applies to them based on ACMA’s eventual definitions and any further terms ACMA adopts under s 5(4). ACMA’s power to define additional terms means that the practical scope could expand or contract from the direction’s textual contours.

Class‑based differentiation and exemptions

• The standard may treat different classes of carriers and carriage service providers differently and may exempt certain classes from particular provisions (s 6(2)). This creates an enforcement and compliance risk disparity. Regulated entities must be attentive to how ACMA classifies providers; a classification that seems benign could carry substantive compliance obligations or, alternatively, carve‑outs that advantage competitors. The direction does not prescribe classification criteria; ACMA will determine them.

Requirements that drive technical and disclosure costs

• The objectives require comparability, standardised service metrics, explanations of methodology and limitations, and capability for data extraction (s 7(1)(a)-(b)(i)-(vi)). Implementing these features can impose non‑trivial technical costs: aligning modelling methodologies with ACMA’s expectations, adopting common service metrics, building data export APIs or downloads, and preparing plain‑language descriptors linked to technical thresholds. Entities should anticipate both one‑off mapping and publication development costs and ongoing maintenance costs to keep maps up to date.

Accessibility obligations

• The instrument requires compliance with WCAG 2.2 or replacement accessibility guidelines (s 7(1)(b)(iv)). Achieving WCAG conformance may require changes to web‑based map viewers, alternative text for visual elements, keyboard navigation, and accessible data downloads. Accessibility compliance will have development costs and potentially timeline implications.

Data extraction versus privacy/confidentiality

• The standard must enable extraction of published map data for analytical purposes (s 7(1)(b)(vi)). The instrument does not address privacy, commercial confidentiality or security constraints that may apply to raw datasets. Providers should prepare for ACMA to set formats and possible access controls that balance extractability with confidentiality constraints. Absent clear rules in the direction, ACMA will need to reconcile these competing considerations.

Multiplicity of technologies and complexity

• The direction requires maps to capture information for different network technologies or platforms, including LEO satellite Direct to Device services (s 7(1)(b)(vii); s 7(1)(c)). Mapping heterogeneous technologies with different coverage characteristics (terrestrial cell sites, fixed wireless, and satellite beams) raises modelling complexity and comparability challenges. Entities that offer multi‑technology coverage will need integrated modelling approaches and possibly multiple layers of representation for the same geography.

“Reasonable likelihood” and methodological standards

• The direction asks for “appropriate modelling methodologies and assumptions so there is a reasonable likelihood they represent on‑ground experience” (s 7(1)(b)(i)). This phrasing is substantive but not prescriptive. It creates an evidentiary standard ACMA may operationalise in the standard, potentially requiring validation against the National Audit or field measurements. Providers should anticipate requirements for model validation and documentation.

Ambiguities left to ACMA

• ACMA may define any terms necessary to implement the standard (s 5(4)). That gives ACMA significant drafting discretion. Where terms are currently ambiguous in the direction (for example “up‑to‑date”, “useful information”, “reasonably expected service levels”), the practical obligations will hinge on ACMA’s definitions and thresholds.

No penalties specified here

• The instrument does not contain enforcement or penalty provisions (see Penalties and enforcement). This means regulated entities must look to the forthcoming standard for the enforcement architecture; stakeholders cannot rely on the direction to provide clarity about sanctions or compliance protocols.

In short, the principal "gotchas" are tight deadlines for ACMA and industry, scope definition sensitivities, potential for class‑based differentiation or exemptions, substantive modelling, data export and accessibility obligations that carry development cost, and significant drafting discretion left to ACMA which will determine practical compliance burdens and enforcement exposure.

Because the instrument delegates the substantive obligations to an ACMA standard, compliance begins with preparing for the requirements the standard is directed to include. The following practical steps map directly to provisions in the direction and target the likely operational obligations ACMA will impose.

1. Inventory services and map scope against the Relevant Mobile Telecommunications Service definition

• Review your service portfolio against the direction’s definition: public supply; usable while moving continuously between places; not Wi‑Fi; customer equipment not in physical contact with the network; not a smart device; enables voice/SMS or data/internet (s 4). Identify services that fall within and those that sit near the margins (for example fixed wireless, tethered services, IoT specialisations). Because ACMA may define additional terms (s 5(4)), document technical attributes that may influence classification.

2. Prepare modelling and measurement methodologies

• The standard must incorporate appropriate modelling methodologies and assumptions that have a reasonable likelihood of representing on‑ground experience (s 7(1)(b)(i)). Collate existing propagation models, drive‑test datasets, user experience measurements, and any third‑party field data you possess. Prepare validation documentation showing how your models map to field measurements and the National Audit findings (s 7(2)). Plan for model transparency: ACMA must require explaining methodologies and assumptions (s 7(1)(b)(v)), so prepare clear methodological descriptions and evidence supporting key modelling choices.

3. Standardise service metrics and visualisation

• The standard requires a standardised approach to service metrics (s 7(1)(b)(ii)) and visual representations accompanied by plain‑language descriptions of indicative end‑user activities (s 7(1)(b)(iii)-(iv)). Map your internal metrics (e.g. RSRP/RSRQ, SINR, throughput, latency, call success rates) to the likely metrics ACMA will select. Draft proposed plain‑language descriptors that translate technical thresholds into user activities (e.g. “suitable for HD video streaming” at X throughput). Prepare layered map visualisations that can represent different technologies and service levels.

4. Build accessibility and usability into publication platforms

• The direction mandates compliance with WCAG 2.2 or replacement guidelines (s 7(1)(b)(iv)). Ensure your public map viewers meet WCAG success criteria: keyboard access, screen reader compatibility, sufficient colour contrast, and accessible data downloads. Budget for accessibility testing and remediation.

5. Implement data extractability and API readiness

• The standard must enable extraction of published map data for analytical purposes by other organisations (s 7(1)(b)(vi)). Design exportable datasets or APIs with clear schema documentation. Consider common geospatial formats (geoJSON, shapefiles, CSV with coordinate references), data licensing statements, and metadata describing methodology and limitations (s 7(1)(b)(v)). Plan for capacity to serve third‑party analytical queries while managing load, security and any confidentiality constraints.

6. Account for multiple technologies including satellites

• The direction requires maps to capture information for different network technologies including LEO direct‑to‑device (s 7(1)(b)(vii); s 7(1)(c)). Prepare separate layers or data attributes to represent terrestrial and non‑terrestrial coverage, and document assumptions about handover, latency and capacity for each platform. Where satellite service footprints differ materially from terrestrial coverage, provide clear explanatory notes.

7. Prepare transparent limitation statements

• The standard must require publication of explanations of limitations such as indoor coverage, expected coverage for users in moving vehicles, congestion‑prone areas and known blackspots that conflict with predicted coverage (s 7(1)(b)(v)). Draft limitation statements that map to technical caveats and include suggestions for user tests or field measures that help end‑users assess likely experience.

8. Engage with ACMA and monitor the National Audit findings

• ACMA must have regard to the National Audit of Mobile Coverage findings (s 7(2)). Engage with ACMA during its consultation and provide empirical evidence, model validation results and pragmatic proposals for comparability. If the National Audit contains datasets or methodologies relevant to your service areas, reconcile your models with the Audit’s findings and be prepared to explain departures.

9. Plan for class‑based treatment and potential exemptions

• Because ACMA may treat different classes of carriers and carriage service providers differently or exempt classes from particular provisions (s 6(2)), prepare submissions that explain why your operation should be classified in a particular way (e.g. small regional operator, specialised mobility provider). Provide data to support any requests for phased compliance, scaled obligations or exemptions.

10. Document processes and governance for updates

• The standard must be capable of being varied by ACMA over time (s 5(3)). Establish internal governance to monitor ACMA consultations, implement standard updates, and maintain periodic map refresh cycles so published maps remain “up‑to‑date” as required by the objectives (s 7(1)(b)). Maintain versioned datasets and changelogs documenting methodology changes.

11. Legal and compliance assessment

• Until ACMA publishes the standard, the direction does not specify enforcement. Nevertheless, perform a legal review of privacy, data sharing and contractual obligations that could constrain data extractability or public disclosure. Prepare proposed redaction or aggregation strategies where raw data cannot be publicly released for legitimate confidentiality or privacy reasons; outline these to ACMA during consultation.

12. Budget and timeline alignment

• Align implementation project plans with ACMA’s deadlines: determination by 31 March 2026 and commencement by 30 June 2026 (s 5(2)). Build contingency for iterative changes following ACMA consultation or variation.

Following these steps will not guarantee compliance , because the exact obligations depend on ACMA’s standard , but they map directly to the direction’s specified objectives and constraints (s 5; s 6; s 7) and put regulated entities in a position to respond effectively when ACMA publishes the standard.