Submission to Australian Competition and Consumer Commission - Wholesale and Networks Record Keeping Rules
24 April 2026
ACCAN recently submitted to the Australian Competition and Consumer Commission (ACCC) in response to its consultation on the proposed Wholesale and Networks Record Keeping Rule (Wholesale and Networks RKR).
The submission supports the ACCC’s record keeping rules review and its goal to streamline reporting requirements, ensuring the reported data remains targeted, useful, and sufficiently transparent to equip stakeholders to develop evidence-based policy and regulatory initiatives that support the productivity of the telecommunications sector.
In response to the ACCC’s consultation questions, ACCAN recommended:
Including direct indicators of network congestion for NBN connectivity virtual circuit acquisition.
ntroducing record keeping requirements to gather wholesale and service-level data on speed, data caps, and throttling practices.
Adopting an SA1 geographic identifier for wholesale home wireless broadband to enable meaningful analysis of market dynamics, particularly in regional, rural, and remote areas.
Additional record keeping requirements to gather data on service continuity arrangements between wholesale providers and carriage service providers.
