AGL recently responded to the Australian Communications and Media Authority’s (ACMA) proposal to introduce a Statement of Expectations for the telco industry which is aimed at improving outcomes for vulnerable consumers.

The Statement of Expectations is intended to sit alongside a number of existing regulatory obligations under Telecommunications Consumer Protection Code (TCP Code). The Statement of Expectations focuses on telcos proactively identifying and protecting vulnerable consumers through five priority areas: internal business practices, selling and contracting, customer service, financial hardship, and disconnection.

AGL generally supports the goals and outcomes under each of the five priority areas. We do, however, urge ACMA to clarify the purpose and timeline of the proposed Statement of Expectations as it is currently unclear whether the comprehensive outcomes and examples will serve as minimum standards of compliance. Some of the prescriptive examples in the Statement of Expectations appear to overlap or duplicate existing obligations under the TCP Code which could create competing sets of compliance obligations for telcos.

Levering our extensive experience with consumer vulnerability frameworks in the energy industry, we believe that in some circumstances it is appropriate for telcos to proactively identify circumstances which make consumers susceptible to vulnerability, such as extreme events, including bushfires, floods and the pandemic. Broadly, we advocate for consumer self-identification to access available assistance and support frameworks but caution ACMA on the unintended outcomes of introducing regulatory obligations which require telcos to proactively identify whether the consumer is vulnerable during each interaction.

You can read the full submission here.