Predictive Coverage Modelling Methodology and predictive coverage modelling assumptions. The instrument defines a Predictive Coverage Modelling Methodology as any method that applies RF link budget calculations to predict signal performance and generates predictive coverage maps under conditions defined in the method (s 5(2)). Predictive coverage modelling assumptions are defined to include the signal-strength coverage thresholds for 4G and 5G specified in Table 1 in Part 1 of Schedule 1 and the standardised modelling assumptions (methodology parameters and associated values) in Table 2 in Part 1 of Schedule 1 (s 5, definition). The instrument thus mandates both a modelling approach and standardised parameters for that modelling. The text refers to Schedule 1 for the concrete thresholds and parameter values; these tables are therefore an integral technical component of compliance.

Mobile network coverage map and network coverage information. A mobile network coverage map is a map prepared in accordance with s 7 (s 5, definition by reference to s 7(1)). Network coverage information is required to set out the coverage levels that can reasonably be expected in a given geographical area for each Relevant Mobile Telecommunications Service represented, and must include visual representations and plain language descriptions, a legend with specific labels, coverage level information referenced to Table 3 in Schedule 1, and any assumptions and limitations affecting accuracy including the general mobile coverage map information set out in Part 3 of Schedule 1 (s 7(3)-(4)).

Publication and accessibility. The instrument prohibits publication of any map representing 4G/5G network coverage unless it is a mobile network coverage map (s 8(1)). It requires publication on an operator’s website in a clearly labelled, prominent section that is accessible to any person without login and easy to find (s 8(2)-(4)). The network coverage information must be prominently displayed with the map (s 8(5)). Publication must permit extraction of underlying geospatial data by a list of specified organisations for analytical purposes, and publication must meet the Level AA or Level AAA success criteria of the Web Content Accessibility Guidelines (s 8(6), (8)).

Data sharing duties. The instrument imposes duties on Mobile Network Operators to provide MVNO wholesale customers with access to maps and all network coverage information in a format that allows the MVNO to publish in accordance with s 12, plus other reasonable assistance (s 10). It imposes similar obligations between MNOs where a network unit is used by both under an agreement (s 11). When an MNO updates a map, it must give access to updated material as soon as possible (ss 10(3), 11(3)).

Maintenance and review. Published maps must be kept up-to-date; operators must update as soon as practicable after becoming aware of a change and must review maps at least once every three months (s 9). MVNOs who publish must similarly keep maps current and must publish updated maps as soon as practicable after receiving updated material from an MNO (s 13).

Definitions and cross-references. The instrument reuses key statutory terms from the Telecommunications Act 1997 and other Acts, and the Direction is an instrument that sets the broader objectives the standard is intended to implement (s 3, s 4(2), s 6). The Web Content Accessibility Guidelines 2.2 (WCAG 2.2) are adopted as the accessibility benchmark (s 5, definition). The instrument also refers to the NSW Government Telecommunications Authority, the Australian Maritime Safety Authority, the Custodian under a separate Act, and emergency service organisations as specified entities in the extraction obligation (s 5, s 8(6)).

Primary regulated entities. The instrument explicitly applies to Mobile Network Operators and Mobile Virtual Network Operators that supply Relevant Mobile Telecommunications Services (s 4(1)). A Mobile Network Operator is defined as a carrier or carriage service provider that operates a telecommunications network to supply Relevant Mobile Telecommunications Services (s 5). A Mobile Virtual Network Operator is a carriage service provider other than a Mobile Network Operator who supplies Relevant Mobile Telecommunications Services (s 5). The definitions import statutory meanings from the Act for carrier, carriage service provider and telecommunications network (s 5 note 2). Retail customers and wholesale customers are defined; a wholesale customer is a carrier or carriage service provider (s 5).

Wholesale customers and MVNOs. The instrument creates direct compliance dependency in wholesale relationships. Where a Mobile Network Operator has a wholesale customer who is an MVNO, the MNO must give the MVNO access to the map in a publishable format, the network coverage information, and such assistance as is reasonably necessary to allow MVNO compliance (s 10(2)). If an MNO does not comply with these obligations, the MVNO’s own duty to publish is disapplied to that extent (s 12(7)). Thus MVNOs are affected both as obliged publishers and as dependent on MNO cooperation.

Specified organisations with data extraction rights. The instrument gives a named set of public and emergency-related bodies the right to extract underlying geospatial map data from published maps for analytical purposes: emergency service organisations, the ACCC, the ACMA, the AMSA, the Custodian, the Department administered by the Minister for the Act, the NSW Telco Authority, and other public bodies with emergency management functions (s 8(6)). Those organisations can obtain extractable geospatial data; the instrument permits Mobile Network Operators to require verification steps but insists that enabling extraction is necessary (s 8(6)-(7)).

Customers and the public. The maps must be published in a freely accessible, easy-to-find website section and must be accompanied by plain language descriptions (s 8(4), s 7(4)(a)(ii)). This places obligations on operators to convey coverage expectations to retail customers and prospective customers as part of public disclosure.

Regulatory agencies and Ministers. The instrument is made under the Telecommunications Act 1997 and in accordance with a Ministerial Direction (s 3). The ACMA is the sponsor of the instrument under the Act (s 3). The Direction is expressly referenced as setting objectives the instrument must give effect to (s 4(2)(b) and s 3 note). The instrument therefore creates duties that are relevant to regulator monitoring and to public policy implementation under the Direction, and it gives the ACCC and ACMA data extraction rights (s 8(6)).

Organisations not named. The instrument permits Mobile Network Operators to allow other persons to extract map data beyond the named list, but does not require such wider release (s 8 note). The instrument also permits MNOs to provide maps representing non-4G/5G technologies; those other maps are not governed by this instrument, although the MNO may publish them (s 8 note 2).

Preparation duty for Mobile Network Operators. A Mobile Network Operator must prepare a mobile network coverage map that visually represents the network coverage information for all Relevant Mobile Telecommunications Services using 4G or 5G that it supplies or offers to supply to wholesale and retail customers (s 7(1)). The Operator must do so using a Predictive Coverage Modelling Methodology and the predictive coverage modelling assumptions (s 7(2)). The map must include or be accompanied by clear, up-to-date and useful information about expected service coverage levels in a given geographical area (s 7(3)).

Content requirements. Network coverage information must include visual representations and plain language descriptions, a legend with the labels “Good”, “Moderate”, “Basic” and “No Coverage”, and the coverage level information specified in Table 3 Part 2 of Schedule 1 (s 7(4)(a)(i)-(ii)). The map must also include any assumptions and limitations affecting accuracy, including the general mobile coverage map information in Part 3 of Schedule 1 (s 7(4)(b)). Maps for both 4G and 5G must include this information (s 7(5)).

Publication and public access duties. A Mobile Network Operator must not publish any map of 4G/5G network coverage unless it is a mobile network coverage map prepared in accordance with s 7 (s 8(1)). Operators must publish the map and associated network coverage information on their website, first by no later than 30 June 2026, and keep it published thereafter (s 8(2)-(3)). Publication must be prominent, in a clearly labelled section accessible without login and easy to find (s 8(4)). The network coverage information must be prominently displayed with the map and easily accessible when using the map (s 8(5)).

Accessibility and extractability rights. Operators must publish the map in a way that permits specified organisations to extract the underlying geospatial map data for analytical purposes, namely a listed set of emergency services, government agencies and public bodies (s 8(6)). The instrument states it is immaterial whether the Operator must take steps after publication to enable extraction, which allows the Operator to require verification or other steps after publication (s 8(7)). Publication must satisfy the Level AA or Level AAA Success Criteria of WCAG (s 8(8)).

Maintenance and review duties. Where a Mobile Network Operator has published a map, it must ensure the map and information are kept up-to-date and must update the map and information as soon as practicable after becoming aware of a change (s 9(2)). The Operator must review the map and information at least once every three months and update if the review reveals changes (s 9(3)).

Duties to MVNOs and other MNOs. If an MNO has an MVNO wholesale customer, the MNO must, as soon as possible after publishing a map that relates to the Relevant Service it supplies to that MVNO, provide the MVNO with access to the map in a format that allows the MVNO to publish in compliance with s 12, access to all network coverage information, and reasonable assistance necessary to allow the MVNO to comply (s 10(2)). Similar duties apply between MNOs if they share network units under an agreement (s 11(2)). Updates must be provided as soon as possible after the MNO updates a map (ss 10(3), 11(3)).

MVNO publication duties. Subject to s 12(7), an MVNO must publish a mobile network coverage map and the network coverage information for all Relevant Mobile Telecommunications Services using 4G or 5G it supplies or offers to supply, on its website, first no later than 30 June 2026 and thereafter continuously (s 12(2)-(3)). The MVNO’s published map must be substantially the same as the most recent map and information provided under s 10 and must indicate the name of the Mobile Network Operator that provided the access (s 12(5)). The MVNO must also meet WCAG Level AA or AAA (s 12(6)).

Right to require verification steps. The instrument specifically contemplates that a Mobile Network Operator may take one or more steps, after publication, to enable a specified organisation to extract geospatial map data, and gives an example that a Mobile Network Operator may verify that a person seeking extraction is, or represents, a specified organisation (s 8(7)). That is an express recognition of some gatekeeping on extraction, subject to the obligation to enable extraction.

Content and technical cross-references. The instrument ties key obligations to the contents of Schedule 1 (for thresholds, assumptions and coverage-level descriptions) and the Direction (for high-level objectives) (s 5 definitions, s 4(2)(b)). The web accessibility standard is tied to WCAG 2.2 (s 5 definition).

No penalties specified in text. The instrument does not itself set out civil penalties, offences or enforcement processes within the provided text. It is made under the Act and in accordance with the Direction, and the Act and Direction will therefore be the primary legal framework for any enforcement or remedial action (s 3; see also s 6 notes that reference the Acts Interpretation Act and Legislation Act).

The instrument as provided does not specify express penalties, fines, or criminal offences for failure to comply with its provisions. The text contains no dedicated penalties section, and it does not set out enforcement processes within the instrument itself. The instrument is made under subsection 125AA(1) of the Telecommunications Act 1997 and in accordance with the Direction (s 3). That statutory source is therefore relevant to any enforcement framework but the instrument does not reproduce or restate enforcement powers, civil penalty provisions, or the steps regulators may take in response to non‑compliance.

Where the instrument is silent on specific enforcement mechanisms, enforcement will depend on the broader statutory architecture in which the instrument sits, including the Telecommunications Act 1997 and any powers it confers on the ACMA or other agencies to secure compliance with instruments made under s 125AA and directions given under s 125AA(4). The instrument’s s 6 notes reference section 589 of the Act and general legislative interpretation provisions (s 6 notes), indicating that other Act provisions and regulatory powers are part of the legal context. The instrument also grants rights to specified public bodies to extract geospatial data from published maps (s 8(6)), which could be used to monitor compliance.

The instrument identifies the ACMA in its authority clause and lists the ACCC and ACMA among bodies entitled to extract geospatial data (s 3; s 8(6)). That creates an evidential pathway for those bodies to obtain the underlying data and thus to undertake analysis that may inform enforcement or regulatory action. The instrument allows Mobile Network Operators to require reasonable verification steps for extraction rights (s 8(7)), which affects the mechanics of data sharing but does not relieve the underlying obligation to enable extraction.

Because the instrument does not itself provide penalties, practitioners should consider the following implementation points when assessing enforcement risk: (1) the Telecommunications Act and the Direction, which are the authority for the instrument, may contain enforcement powers or sanctioning mechanisms applicable to failure to comply with legislative instruments made under s 125AA; (2) public bodies with extraction rights can obtain underlying geospatial data which could be used as the factual basis for regulatory follow-up; (3) contractual consequences between MNOs and MVNOs may apply where publication or access obligations are not met, including commercial dispute resolution under wholesale agreements.

In short, the instrument creates duties and data access obligations but does not on its face specify penalties or enforcement steps. Any regulatory or legal sanctions would need to be identified in the Act, the Direction or other statutory instruments and policies not reproduced in the text provided. Readers and regulated entities should therefore consult the Telecommunications Act 1997, the Direction, and ACMA/ACCC guidance to understand the enforcement regime that will apply in practice.

Made under the Telecommunications Act and Direction. The instrument is expressly made under subsection 125AA(1) of the Telecommunications Act 1997 and in accordance with the Direction (s 3). The instrument is intended to give effect to objectives set out in the Direction (s 4(2)(b)). Those references mean that the instrument must be read in the statutory context of the Act and the Direction; obligations in this instrument are framed as particularised industry-standard obligations under the Act. Any enforcement, interpretation or limits on the instrument will therefore be mediated through the Act and the Direction.

References to other Commonwealth and state instruments. The instrument incorporates or refers to other instruments and bodies. It adopts the Web Content Accessibility Guidelines (WCAG 2.2) as the accessibility benchmark for publication (s 5). It references the Telecommunications (Consumer Protection and Service Standards) Act 1999 by adopting the same meaning for Custodian and for emergency service organisations via a cross‑reference (s 5). It identifies the NSW Telco Authority established under the Government Telecommunications Act 2018 (NSW), signalling an intersection with state statutory bodies for purposes of data extraction (s 5). Section 6 confirms that references to other legislative instruments are to be read as in force from time to time (s 6).

Interaction with commercial contracts and wholesale supply arrangements. The instrument creates duties that sit alongside existing commercial wholesale arrangements. It directly requires MNOs to provide MVNO wholesale customers with access to maps and all network coverage information and to provide reasonable assistance for the MVNO to publish (s 10). It also requires MNOs to provide access to other MNOs where shared network units are used under agreement (s 11). These statutory duties will interact with commercial contractual terms that govern information sharing, confidentiality, intellectual property and data formats. Where a commercial agreement limits disclosure, the MNO’s statutory duty to provide access in the format required to enable MVNO publication (s 10(2)(a)) may call for contract renegotiation or operational workarounds.

Data protection and privacy law. The instrument requires the publication of maps and provision of geospatial map data to specified organisations (s 8(6)). The instrument does not address personal data or identify privacy exemptions, but the output and any associated metadata could interact with privacy law and obligations under the Privacy Act for handling data that could be personal or sensitive. The instrument does not displace privacy obligations, so operators should consider privacy law when publishing detailed geospatial data and when sharing data with third parties beyond the named bodies.

Web accessibility and disability law. By mandating WCAG Level AA or AAA success criteria for maps and associated information (ss 8(8), 12(6)), the instrument interacts with accessibility obligations under other Commonwealth instruments or state laws. Operators should ensure compliance with WCAG 2.2 and with any applicable accessibility statutory obligations, noting the instrument’s explicit adoption of a version of WCAG in s 5.

Regulatory reporting and oversight. The instrument provides extraction rights to regulators and public bodies, including the ACMA and ACCC (s 8(6)). Those agencies may therefore use the geospatial data to monitor coverage, competition or compliance. The instrument itself does not prescribe reporting to those agencies, but the extractability requirement creates an operational interface for regulatory oversight.

State and emergency-response coordination. The inclusion of the NSW Telco Authority and public bodies whose functions include emergency management among the specified organisations entitled to extract geospatial data (s 8(6)) creates a statutory mechanism for state-level and emergency planning bodies to access detailed coverage data. That may affect state planning, emergency response coordination and any state-level regulatory processes that make use of coverage data.

Other Acts incorporated by definition. The instrument imports definitions from the Telecommunications (Consumer Protection and Service Standards) Act 1999 (s 5) and references other Acts for definitional clarity (s 5 note 2). Practitioners should treat this instrument as one part of a multilayered statutory environment.

The text provided contains the instrument’s formal name and commencement note and repeats a number of sections. It states that the instrument is the Telecommunications (Mobile Network Coverage Maps) Industry Standard 2026 and that it commences at the start of the day after it is registered (s 1; s 2 note). The instrument is made under subsection 125AA(1) of the Telecommunications Act 1997 and in accordance with the Direction (s 3). The Direction itself was given by the Minister under subsection 125AA(4) and is publicly accessible (s 3 note).

No amendments are recorded within the text provided. The instrument contains no express amendment history, transitional provisions or savings clauses in the portion supplied. Section 6 establishes that references to other legislative instruments are to be read as those instruments are in force from time to time and that other instruments and writings referenced are to be read as in force or existing from time to time (s 6). That general interpretive rule means later amendments to cross‑referenced instruments will apply as they stand from time to time.

Because the instrument is a legislative instrument made under the Act, any formal amendment or repeal would follow the processes set out in the Acts Interpretation Act 1901 and the Legislation Act 2003. The s 6 notes explicitly point to those interpretive statutes (s 6 notes). Practitioners seeking the amendment history should consult the Federal Register of Legislation entry for this legislative instrument, which will record registration date, explanatory materials and any subsequent amendments, and should also check the Direction referenced in s 3 for its own amendment history.

The text supplied duplicates several sections. The repetition appears to be an artifact of the source extract rather than individual amending acts. The instrument itself references Schedule 1 for modelling thresholds and other technical parameters. Any change to those technical parameters would require amendment of Schedule 1 or a new instrument that replaces or modifies the standard, which would be recorded on the Federal Register of Legislation.

Absent any recorded amendments in the provided text, readers should assume the instrument as supplied is the operative version and should monitor the Federal Register of Legislation, ACMA releases and the Direction for any future amendments to the standard, the Direction, or associated schedules.

The instrument as provided contains no references to judicial decisions, administrative determinations or litigation history. It does not name any cases, and it does not include a chronology of legal challenges. The instrument is a legislative instrument made under the Telecommunications Act 1997, and any challenges to its validity or to its interpretation would be matters of public record in courts or tribunals, but none are referenced in the text provided.

The instrument does make cross-references to the Telecommunications Act 1997 and other statutory instruments such as the Direction and the Telecommunications (Consumer Protection and Service Standards) Act 1999, which are themselves legislative sources that may have been the subject of past litigation. Those materials are not reproduced here and no case law is cited in the instrument.

Given the absence of litigation references, practitioners seeking precedent on enforcement, interpretation of similar standards, or judicial attitudes to coverage mapping obligations must search external databases for cases that engage the Telecommunications Act, the ACMA’s industry standard-making powers under s 125AA, or disputes between MNOs and MVNOs about information provision. The instrument’s text does not indicate that any such litigation has occurred in relation to this specific instrument.

For regulatory risk assessment, note that the ACCC and ACMA are among bodies with authorised rights to extract data (s 8(6)). Any disputes over whether an operator’s published map complies with the instrument or over the sufficiency of access to MVNOs could generate administrative or judicial disputes, but no litigation concerning those points is included in the instrument itself.

Obligation to publish no earlier-than-compliant maps. Section 8(1) is an absolute prohibition: a Mobile Network Operator must not publish or otherwise make publicly available a 4G/5G coverage map unless it is a mobile network coverage map prepared in accordance with s 7. That means operators cannot simply repurpose legacy coverage graphics or commercially produced maps that do not meet the instrument’s modelling method, assumptions and content requirements. The phrase “must not publish” is categorical and applies to any map representing 4G/5G network coverage (s 8(1)).

Dependence on Schedule 1 technical content. The instrument delegates substantive threshold and modelling parameter content to Schedule 1: predictive coverage modelling assumptions are defined by Table 1 and Table 2 of Part 1 of Schedule 1 and coverage level information is specified in Table 3 of Part 2 of Schedule 1 (s 5; s 7(4)(a)(ii)). The instrument does not reproduce those tables in the text supplied. Compliance therefore requires consulting Schedule 1 and applying the exact thresholds and methodology parameters stated there. Failure to adhere to those specific parameters could render a map non‑compliant, even if it appears technically rigorous.

Mandatory legend labels and plain language descriptions. The map must include a legend with four specific coverage level labels and meet Table 3’s coverage-level content (s 7(4)(a)(i)-(ii)). Operators that use different label terms or colour schemes without exactly matching the required text and coverage-level information risk non‑compliance. Plain language descriptions are required, so technical maps without accessible explanatory text will fall short of the requirement for “clear, up-to-date and useful information” (s 7(3)).

Data extraction must be enabled, but verification is permitted. The instrument requires publication in a manner that provides the capability for specified organisations to extract underlying geospatial map data (s 8(6)), but it also states it is immaterial whether an operator has to take steps after publication to enable extraction, giving an example that the operator may verify the identity of the extractor (s 8(7)). Operators may therefore impose some gatekeeping steps. The risk here is operational: if the extraction pathway is onerous, a specified organisation may regard the map as not sufficiently extractable in practice. The obligation is to provide capability; the permitted verification steps could create frictions that prompt complaints.

Strict web publication requirements. Publication must be prominent, in a clearly labelled section, accessible without login, easy to find, and with network coverage information prominently displayed with the map (s 8(4)-(5)). Buried PDF documents, maps behind obscure menus, or maps requiring an account will not meet the accessibility and discoverability tests. The instrument also requires WCAG Level AA or AAA success criteria compliance (s 8(8), s 12(6)). Achieving Level AAA across complex interactive geospatial maps can be technically demanding and may require substantial web development and testing.

Quarterly review and prompt updates. Operators must review maps at least every three months and update them as soon as practicable after becoming aware of changes (s 9(2)-(3)). Frequent network changes, temporary outages, or commercial network-sharing arrangements could impose a recurring operational cost to maintain compliance. The term “as soon as practicable” will require operators to document update workflows and evidence timeliness.

MVNO publication dependency and partial exemption. MVNOs must publish substantially the same map as provided by the MNO and include the MNO’s name (s 12(5)). However, if the MNO has not complied with s 10 in giving access, the MVNO’s obligation to publish does not apply to that extent (s 12(7)). Practically, this creates an interdependent compliance chain: MVNO compliance can be frustrated by MNO non‑compliance, and MVNOs must be prepared to document attempts to obtain access to rely on the exemption. Conversely, MNOs must be prepared to provide publishable data format and assistance promptly.

Format and metadata requirements for “publishable format”. The instrument requires an MNO to provide an MVNO with access to the map in a format that allows the MVNO to publish in accordance with s 12 (s 10(2)(a)). The instrument does not prescribe specific file formats, APIs or data schema, but compliance will require agreeing formats that support MVNO web publication and meet extractability and accessibility requirements. Disputes about what constitutes a publishable or extractable format may arise.

Interplay with commercial confidentiality and IP. The instrument requires sharing of network coverage information and geospatial data with MVNOs, other MNOs, and specified public bodies (ss 10, 11, 8(6)). Existing confidentiality clauses and IP ownership terms in wholesale or infrastructure-sharing contracts may need to be revisited. The instrument does not excuse contractual confidentiality, so operators will likely need contractual amendments or controlled disclosure protocols to reconcile statutory duties with commercial rights.

Scope limited to 4G and 5G. The instrument prohibits publishing any 4G/5G coverage map unless it complies with ss 7-8, but it expressly permits MNOs to publish coverage maps for other technologies outside the instrument (s 8 note 2). Operators that offer multi-technology coverage must manage multiple map products and ensure that only compliant 4G/5G maps are published under the prescribed format and method.

WCAG Level AA or AAA selection. The instrument requires satisfaction of Level AA or Level AAA success criteria (s 8(8), s 12(6)). That wording could be read as permitting either Level AA or Level AAA. Operators should decide which level they will meet and document that choice, because satisfying Level AAA is typically more onerous. The instrument does not specify which one to choose, but compliance requires meeting one of them.

No express penalties in instrument text. Because the instrument does not specify penalties, regulated entities cannot rely on a penalty schedule contained in the text. Enforcement mechanisms will depend on the Act, the Direction and regulator policies outside the instrument. This creates legal uncertainty about consequences for non-compliance and increases the importance of early dialogue with the ACMA and counterparties.

Checklist for Mobile Network Operators (MNOs)

1. Prepare the technical map

   • Use a Predictive Coverage Modelling Methodology as defined in s 5(2): apply RF link budget calculations and generate predictive coverage maps.
   • Apply the predictive coverage modelling assumptions specified in Schedule 1 Table 1 and Table 2 (s 7(2); s 5 definition). Obtain Schedule 1 and ensure modelling parameters and threshold values are implemented exactly.

2. Include the required content

   • Provide network coverage information that is clear, up-to-date and useful, stating expected coverage in geographical areas (s 7(3)).
   • Include the mandatory legend labels “Good”, “Moderate”, “Basic” and “No Coverage” and the coverage-level information specified in Table 3 Part 2 of Schedule 1 (s 7(4)(a)(i)-(ii)).
   • Publish the assumptions and limitations affecting accuracy, including the general mobile coverage map information in Part 3 of Schedule 1 (s 7(4)(b)).

3. Publish on the website

   • Publish the map and the network coverage information no later than 30 June 2026 and maintain publication thereafter (s 8(3)).
   • Place maps in a prominent, clearly labelled section that is accessible without login and easy to find (s 8(4)).
   • Ensure network coverage information is prominently displayed with the map and easily accessible when using the map (s 8(5)).

4. Ensure accessibility and extractability

   • Conform to WCAG 2.2 Level AA or Level AAA success criteria for the map and associated information (s 8(8)); document testing and remediation actions.
   • Provide capability for specified organisations to extract underlying geospatial map data (s 8(6)); decide on an extraction mechanism (bulk download, API, authenticated portal) and implement it.
   • Implement reasonable verification and gating procedures for extraction consistent with s 8(7), but avoid creating undue friction that would prevent practical extraction.

5. Operationalise update and review processes

   • Conduct formal reviews of the map and coverage information at least once every three months, documenting findings (s 9(3)).
   • Update the map and information as soon as practicable after becoming aware of changes; maintain audit trails and timestamps for updates (s 9(2)).

6. Manage MVNO and other network partner access

   • For wholesale MVNO customers, provide access to the map in a format that allows MVNO publication under s 12, all network coverage information for the map, and reasonable assistance to enable MVNO compliance (s 10(2)).
   • Provide updated maps and information to MVNOs and partner MNOs as soon as possible after updates (ss 10(3), 11(3)).
   • Agree in advance on data formats and metadata required for MVNO publication; consider APIs or shapefile/GeoJSON exports compatible with common web mapping frameworks and accessibility needs.

7. Recordkeeping and governance

   • Maintain records of publication dates, review logs, update actions, access requests from specified organisations and MVNOs, and assistance provided (s 9; s 10).
   • Prepare compliance statements showing that the Predictive Coverage Modelling Methodology and Schedule 1 parameters were applied.

Checklist for Mobile Virtual Network Operators (MVNOs)

1. Obtain map access

   • Request from the MNO the map in a format that allows MVNO publication, all network coverage information, and reasonable assistance (s 10(2)).
   • If access is not provided, document requests and rely on the s 12(7) exemption to the extent the MNO has not complied.

2. Publish substantially the same map

   • Publish the map and network coverage information substantially the same as the most recent map and information provided, and include the supplying Mobile Network Operator’s name (s 12(5)).
   • Publish by 30 June 2026 and maintain publication thereafter (s 12(3)).

3. Accessibility and presentation

   • Ensure the MVNO’s published map and the network coverage information meet WCAG Level AA or AAA success criteria (s 12(6)).
   • Publish in a prominent, clearly labelled website section accessible without login and easy to find (s 12(4), s 8(4)).

4. Update obligations

   • If the MVNO is given access to an updated map, publish the updated map as soon as practicable and in accordance with the publication requirements (s 13(3)).
   • Maintain records of when updates were received from the MNO and when they were published.

Technical and operational recommendations

• Consult Schedule 1 early. The modelling thresholds and methodology parameters in Table 1 and Table 2 and the coverage descriptions in Table 3 are prescriptive technical inputs. Obtain and implement them precisely.

• Establish a geospatial data pipeline. Build internal capability to produce exportable geospatial data (GeoJSON, shapefiles, GeoTIFFs) and to expose an authenticated but low-friction extraction mechanism for specified organisations. Ensure metadata and coordinate reference systems are documented.

• Accessibility testing. Engage accessibility specialists to validate WCAG 2.2 Level AA or AAA compliance for interactive maps, legend text, alternative text, keyboard accessibility, contrast ratios and machine-readable data. Keep test certificates and remediation logs.

• Quarterly review workflow. Implement an automated quarterly review that reconciles network configuration changes, maintenance schedules, site builds or decommissions against published maps, and produces an update log showing actions taken and publication timestamps (s 9(3)).

• Contract updates. Review and update wholesale and network-sharing agreements to ensure they enable timely access and permit provision of required data formats and assistance to MVNOs and other MNOs as required by ss 10-11.

• Data governance and privacy. Assess whether any map metadata or exports contain personal or commercially sensitive information and apply privacy and confidentiality controls. Consider redaction or aggregation where privacy laws or contractual obligations require it, while ensuring that the export remains usable for the specified organisations as required by s 8(6).

• Communications and customer-facing text. Prepare plain language descriptions and explanatory notes that align with the coverage-level definitions in Table 3 and Part 3 of Schedule 1. Ensure customer-facing claims about “coverage” are consistent with the published maps to avoid misleading representations.

• Liaison with regulators and named extractors. Proactively engage the ACCC, ACMA, emergency service organisations and other likely extractors to test extraction workflows and confirm that the formats supplied meet their analytical needs. Document any agreed verification processes that will be used to satisfy s 8(7).

• Audit trail for compliance. Maintain an auditable record linking the modelling inputs (RF link budget calculations, parameter values from Schedule 1), the generated maps, publication artifacts and extraction logs to demonstrate compliance if a regulator requests evidence.

By following the statutory prescriptions in ss 7-13 and implementing the operational and technical measures described above, operators can align internal processes with the instrument’s requirements and create the documentation and controls needed to demonstrate compliance.