Proposal to make the mobile coverage mapping standard

The submission recommends the Australian Communications and Media Authority:

1. Amend descriptions across all coverage levels to ensure they clearly reflect real-world consumer usage.

2. Include additional disclosures regarding network congestion, known blackspots, and coverage for stationary outdoor users and users inside moving vehicles.

3. Maintain prescribed thresholds without flexibility to ensure consistency across all coverage maps.

4. Retain Web Content Accessibility Guidelines 2.2 as the accessibility standard but specify that Level AA conformance is required as a minimum.

5. Specify additional modelling parameters, including clutter models, to improve comparability between carriers.

6. Support the quarterly update requirement as a minimum standard, with requirements to ensure substantial network changes are updated within 10 business days.

7. Explicitly require Mobile Network Operators to provide maps that accurately represent Mobile Virtual Network Operators-specific coverage.

8. Remove Note 8(1) to ensure consumers are not confused by multiple maps and Note 8(5) as it is contrary to the Telecommunications (Mobile Network Coverage Maps) Direction 2025 (Cth).

9. Require Mobile Network Operators to make coverage data freely extractable by any member of the public through standardised data workbooks and public application programming interfaces.

10. Amend Section 11 to require that all coverage information from Multi-Operator Core Network arrangements be integrated into a single consumer-facing map on each carrier’s website.

11. Include specific requirements for map usability, including searchability by geographic location, along with filtering by service level and technology type.

12. Include greater specification of prominence requirements for coverage maps on websites.

13. Introduce an effective and easy-to-use consumer challenge feature.

14. Require carriers to link their coverage maps to the National Audit of Mobile Coverage.