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ACCAN’s Comprehensive Views on the ACCC’s Consultation on NBN Co’s RMA proposal

5 November 2025

Background 

ACCAN has submitted its comprehensive views on the Australian Competition and Consumer Commission (ACCC)’s consultation on NBN Co’s proposed Replacement Module Application (RMA). This is part of ACCAN’s activities under an Australian Government grant to represent consumer voices and interests in the development of the National Broadband Network. 


The comprehensive submission sets out ACCAN’s views on the consultation paper and engagement programs undertaken by NBN Co, following on from a preliminary submission sent to the ACCC on 19 September 2025. The submission includes several attachments, including economic analysis produced by FTI Consulting and a consumer engagement report produced by Cred Consulting, which will be made available below. 


Summary 

NBN Co’s proposed Replacement Module Application (RMA) reflects the first step in a long-term journey to embed consumer-centric decision-making at the heart of the NBN. As the first proposal under the August 2023 Special Access Undertaking (SAU) Variation, the RMA reflects the growing maturity of the communications sector as it adopts regulatory mechanisms designed to secure positive outcomes for consumers.  


While elements of the RMA reflect positive signs of engaging with the needs and preferences of end-users, significant reform is required to strengthen NBN Co’s focus on consumer outcomes and bring the regulatory reset process more in line with the standard set by the Australian Competition and Consumer Commission (ACCC) and Australian Energy Regulatory (AER).  


ACCAN’s submission considers NBN Co’s RMA and assesses its proposal against the consumer and stakeholder input over the pre-and-post-lodgement periods, across the following sections:  

  1. Initial efforts at consumer engagement by NBN Co while positive did not embed consumer preferences. While engagement improved incrementally over the course of the pre-lodgement process, NBN Co did not provide sufficient detail in its proposed expenditure and work programs to facilitate a genuine discussion of consumer priorities. 

  2. NBN Co’s RMA does not reflect the consumer preferences documented in ACCAN’s consumer engagement program. Many capex programs appear to be significantly driven by commercial considerations, including the desire to increase revenues by transitioning consumers to higher-speed services 

  3. NBN Co has not sufficiently explained how its proposals reflect value for money for consumers. While elements of NBN Co’s expenditure proposals will deliver positive, value-for-money outcomes for consumers there remain significant expenditure, such as investment in the Hybrid-Fibre Coaxial (HFC) network, that have not been justified.  

  4. NBN Co’s investment governance framework is immature and requires strengthening. While elements of NBN Co’s proposal may be justifiable, the RMA lacks sufficient evidence and detail of the methodology adopted by NBN Co, undermining public and regulatory trust in their proposal. 


In addition to the above assessment of NBN Co’s engagement program and proposed expenditures, ACCAN has also addressed the ACCC’s consultation questions in order to promote the long-term interest of end-users (LTIE) and ensure a robust regulatory reset process.  


ACCAN has made a number of recommendations for NBN Co and the ACCC to consider, including: 


Benchmark Service Standards 

  • NBN Co include FTTN and FTTC technologies in its enhancements to benchmark service standards to ensure that underserved premises are not left behind in the second regulatory cycle. 

  • NBN Co consider improvements to the service standard time frames for rural, regional, and remote areas to ensure more equitable service delivery. 

  • ACCC consider additional network performance service standards to measure packet loss, jitter and latency. 

Weighted Average Cost of Capital 

  • ACCC undertake a review of the interaction between the WACC and the Initial Cost Recovery Account (ICRA) in advance of the next regulatory cycle. 

Prudency and Efficiency 

  • ACCC review the impact of changes to NBN Co’s capitalisation policies for capex programs in the current regulatory cycle. 

Entry Level Offer 

  • ACCC schedule a mid-cycle review of the Entry Level Offer for FY27. 

  • Retail price caps be established for the ELO service tier to ensure that excessive margins are not charged on this service. 


Please see ACCAN’s full submission for a detailed list of recommendations and our full analysis on NBN Co’s RMA.




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