Explanatory Statement
Issued by the authority of the Minister for Communications
Telecommunications Act 1997
Telecommunications (Mobile Network Coverage Maps) Direction 2025
Authority
The Telecommunications (Mobile Network Coverage Maps) Direction 2025 (the Direction) is made by the Minister for Communications (the Minister) under subsection 125AA(4) of the Telecommunications Act 1997 (the Act).
Subsection 125AA(4) of the Act enables the Minister to direct the Australian Communications and Media Authority (ACMA) to determine an industry standard that applies to participants in a particular section of the telecommunications industry and deals with one or more matters relating to the telecommunications activities of those participants.
Subsection 125AA(1) of the Act provides that the ACMA may, by legislative instrument, determine an industry standard that applies to participants in a particular section of the telecommunications industry and deals with one or more matters relating to the telecommunications activities of those participants. Subsection 125AA(5) of the Act provides that the ACMA can only determine an industry standard under subsection 125AA(1) if directed to do so by the Minister.
Purpose and operation
This instrument directs the ACMA to make an industry standard that deals with the way mobile coverage maps are prepared and presented to ensure comparability, to provide clear and useful information about the service that can be reasonably expected in a given geographical area, and to capture different network technologies and platforms.
The direction allows the ACMA to incorporate or reflect other matters, to the extent technically and practicably appropriate, that improve the comparability, clarity and utility of mobile network coverage maps.
This instrument is a legislative instrument for the purpose of the Legislation Act 2003. However, it is not subject to disallowance or sunsetting, as it is a direction by a Minister to a person or body (see item 2 of the table in section 9 and item 3 in the table in section 11 of the Legislation (Exemptions sand Other Matters) Regulation 2015).
Details of the Direction are set out in Attachment A.
Background
There are longstanding limitations on the quality and comparability of mobile coverage maps published by the Mobile Network Operators (MNOs – Telstra, Optus, and TPG Telecom). There are no rules on how mobile coverage maps are prepared or presented. Mobile coverage maps are not comparable between operators, do not provide detailed information about quality of coverage, and do not always accurately reflect on-ground experience of end-users.
The lack of standardised mapping makes it difficult for consumers to make informed choices, leading to consumers experiencing poorer than expected connectivity and purchasing products that are unsuitable for where they live and work, and more importantly, not being able to call Triple Zero when they need it. For example, an MNO’s mobile coverage map may indicate that an area has coverage but not provide detail that the quality of coverage is very limited, or that an external antenna is required. Additionally, with the way mobile coverage maps are currently presented, it is unclear where coverage overlaps or where there is only one available service. Where only one service is available, any outage to that service will result in a mobile service Triple Zero outage.
The switch-off of 3G networks in Australia in 2024 highlighted issues with mobile coverage maps that are published by MNOs, and raised concerns about coverage equivalence and the accuracy and differing methodologies. The 2024 Regional Telecommunications Review also highlighted many consumers are dissatisfied with mobile coverage maps and that it does not always align with the actual user experience on-ground.
The Direction takes a broad, objectives-based approach to give the ACMA flexibility to determine the technical components to achieve comparable, clear and useful coverage maps. Improved mobile coverage maps will allow consumers to clearly understand differences in coverage availability and quality between providers. It will also assist the Triple Zero Custodian and the ACMA to better understand the impacts of outages on Triple Zero and to enforce compliance with relevant obligations that require calls to be carried on alternative networks during an outage.
In developing an Industry Standard, the ACMA should consider all international approaches and have regards to the findings of the National Audit of Mobile Coverage to achieve comparable, clear and useful mobile coverage maps. The ACMA should also work collaboratively with the Australian Consumer and Competition Consumer (ACCC) to utilise its knowledge and analyses of mobile network coverage maps.
Impact Analysis
The Office of Impact Analysis has advised that an Impact Analysis is not required for the instrument (OIA25-10472).
On behalf of the Minister, the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts consulted on the proposed instrument with the ACMA, the Australian Telecommunications Alliance and representatives of the telecommunications industry, the Australian Mobile Telecommunications Association, the Telecommunications Industry Ombudsman, the Australian Communications Consumer Action Network, the Australian Competition and Consumer Commission, and the New South Wales Telco Authority.
Statement of compatibility with human rights
As section 42 of the Legislation Act 2003 does not apply to the Direction, being exempted under Part 4 of the Legislation (Exemption and Other Matters) Regulation 2015, a statement of compatibility with human rights is not required under section 9 of the Human Rights (Parliamentary Scrutiny) Act 2011.
Attachment A
Details of the Telecommunications (Mobile Network Coverage Maps) Direction 2025
Section 1 – Name
This section provides that the name of the Direction is the Telecommunications (Mobile Network Coverage Maps) Direction 2025.
Section 2 – Commencement
This section states that the Direction commences the day after it is registered on the Federal Register of Legislation.
Section 3 – Authority
This section states that the Direction is made under subsection 125AA(4) of the Telecommunications Act 1997 (the Act).
Section 4 – Definitions
This section sets out definitions for key terms used in the Direction, namely the expression, ‘Act’, ‘National Audit of Mobile Coverage’ and ‘Relevant Mobile Telecommunications Service’.
The note accompanying this section informs the reader that a number of expressions used in the Direction are defined in section 7 of the Act. The expressions are listed.
Section 5 – Direction to the ACMA
Subsection 5(1) of the Direction provides that the Minister directs the ACMA to determine a Standard under subsection 125AA(1) of the Act.
Under the Act, if the Minister directs the ACMA to make a Standard, the Minister may also direct that the ACMA is to do so within a specified period (paragraph 125AA(4)(b)). Accordingly, subsection 5(2) details the timing of the making and commencement of the Standard.
Paragraph 5(2)(a) provides that the Standard is to be determined no later than 31 March 2026. In developing the Standard, the ACMA must conduct public consultation in accordance with section 132 of the Act.
Paragraph 5(2)(b) specifies that the Standard must commence in full at the earliest opportunity and by no later than 30 June 2026. This timeframe recognises that the telecommunications industry may need to make technical changes to its mapping processes and software, and conduct testing to confirm accuracy of maps.
Subsection 5(3) of the Direction provides that once the Standard is made, the ACMA may vary it in future without the need for a further Ministerial direction, so long as the resulting Standard continues to comply with the provisions of the Direction.
Subsection 5(4) provides that in determining the Standard, the ACMA may define any terms that it considers appropriate or necessary, including terms used in this Direction but not defined in section 4 or in the Act. This is intended to provide additional flexibility for the ACMA.
Section 6 – Application of the Standard
Subsection 6(1) provides that the Standard applies, as relevant, to carriers and carriage service providers who supply Relevant Mobile Telecommunications Services.
Paragraph 6(2)(a) provides that the Standard may deal with matters differently for different classes of carriers and carriage service providers. This recognises that some providers may fall into the same class, yet may have different capabilities depending on their roles.
Paragraph 6(2)(b) provides that the Standard may exempt certain classes of carriers or carriage service providers from particular provisions of the Standard. This provision is designed to ensure that the ACMA has requisite flexibility to tailor requirements of the Standard that it needs to be produce in accordance with the Direction, differently across the particular telecommunications industry sector as appropriate.
Section 6 collectively permits, for example, the ACMA to specify different requirements in the Standard to relevant carriers (such as MNOs) as compared to carriage service providers who are Mobile Virtual Network Operators reselling Relevant Mobile Telecommunications Services (or to exempt MVNOs from certain requirements), as ACMA sees appropriate. This recognises that MVNOs would generally rely on mobile coverage information provided to them by their relevant MNOs.
Section 7 – Objectives of the Standard
Section 7 specifies the objectives the Standard is to give effect to.
Subsection 7(1) provides that the Standard is to be drafted to give effect to the following objectives, as they relate to the telecommunications activities of carriers and carriage service providers who supply Relevant Mobile Telecommunications Services:
Paragraph 7(1)(a) specifies the objective of preparing and publishing mobile coverage maps in a manner that is comparable, including in a standardised manner to the extent necessary to ensure meaningful comparability.
Paragraph 7(1)(b) specifies the objective of preparing and publishing mobile coverage maps in a manner that provides clear, up-to-date and useful information about the service that can reasonably be expected in a given location.
Paragraph 7(1)(b) further specifies that in achieving the objective of paragraph 7(1)(b) the ACMA may incorporate or reflect any or all of the matters outlined in subparagraphs 7(1)(b)(i) – (vi) to the extent technically and practicable appropriate.
Subparagraph 7(1)(b)(i) permits the ACMA to incorporate or reflect appropriate modelling methodologies and assumptions in the preparation and publishing of mobile coverage maps so there is a reasonable likelihood they represent on-ground experience.
Subparagraph 7(1)(b)(ii) permits the ACMA to incorporate or reflect a standardised approach to service metrics in the preparation and publishing of mobile coverage maps. A standardised approach may include representing signal strength, reliability and quality of service levels.
Subparagraph 7(1)(b)(iii) permits the ACMA to incorporate or reflect the visual representation of reasonably expected service levels on mobile coverage maps, accompanied by plain language descriptions of indicative end-user activities at each level in a given geographical location.
Subparagraph 7(1)(b)(iv) permits the ACMA to incorporate or reflect compliance with Web Content Accessibility Guidelines (WCAG) 2.2, or any subsequent replacement or other best practice regarding accessibility.
Subparagraph 7(1)(b)(v) permits the ACMA, in framing the Standard, to incorporate or reflect information that explains the methodologies, assumptions and any limitations around the accuracy of mobile coverage maps. This includes the way coverage is depicted, for example, indoor coverage, coverage from inside a moving vehicle, geographical areas prone to congestion, or known blackspots that conflict with predicted coverage displayed.
Subparagraph 7(1)(b)(vi) permits the ACMA, in framing the Standard, to incorporate or reflect the enabling of data contained in published mobile coverage maps to be extracted by other organisations (such as emergency services organisations) for analytical purposes.
Similarly, subparagraph 7(1)(b)(vii) permits the ACMA to incorporate or reflect any other matter that improves the comparability, clarity, and utility of mobile coverage maps.
Paragraph 7(1)(c) specifies the objective of capturing information that is required under subparagraph 7(1)(b)(iii) for different network technologies or technology platforms used by the carrier or carriage service provider to supply the Relevant Mobile Telecommunications Service. This paragraph includes the example of Low Earth Orbit (LEO) satellite Direct to Device but is also intended to capture, for example, 4G (LTE) and 5G (NR).
Subsection 7(2) provides that in developing the Standard, the ACMA must have regard to all available findings of the National Audit of Mobile Coverage. The intention of this is to ensure that ACMA’s development of the Standard is also informed by the outcomes of the audit which are available to ACMA at the relevant time it is formulating the Standard.