ACCAN’s Submission to the ACCC on the Consultation on retail telecommunications record keeping rules

ACCAN recently submitted to the Australian Competition and Consumer Commission (ACCC) in response to its consultation on retail telecommunications record keeping rules (RKR). 

ACCAN welcomes the ACCC’s proposed Retail Telecommunications RKR and broadly supports the proposed records as a substantial improvement in transparency, accountability, and the depth of information collected on the telecommunications market. 

While these new records are welcome, we have identified opportunities for improvement, such as enabling flagging of concession and hardship products and including records on introductory offers and plan conditions. These additions will support affordability analysis and the identification of potentially harmful selling practices for vulnerable consumers. 

ACCAN emphasises the importance of collecting sufficient data and urges the ACCC to increase the number or duration of the proposed reference periods, as data from only two months of the year is insufficient to adequately address the seasonal nature of the telecommunications market. 

We encourage the ACCC to coordinate with the Australian Communications Media Authority (ACMA) to align definitions, thresholds, and expectations between their record-keeping obligations to minimise the burden on record keepers and better enable direct comparison between their records.