Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Bill 2025

ACCAN recently submitted to the Environment and Communications Legislation Committee on the Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Bill 2025 (the Bill). Our submission highlights the urgent need to mandate affordable Low Earth Orbit satellite (LEOSat)-compatible devices and plans, to set clear statutory objectives, constrain and guide the currently expansive powers vested in delegated legislation, and to strengthen consumer protections to ensure the Universal Outdoor Mobile Obligation (UOMO) delivers on its promise.  

This submission calls on the Environment and Communications Legislation Committee to make the following recommendations in relation to the Bill:

Without considering affordability measures, the UOMO risks making essential communications services unaffordable for many Australians

1. Require PUOMPs to provide baseline affordable mobile plans and access to pre-paid services. 

2. Introduce measures to incentivise the availability of low-cost, LEOSat-compatible devices and establish a device distribution program supporting low-income consumers.

3. Ensure the UOMO applies to both MNOs and MVNOs, and that access is provided to promote competition and affordability for all consumers. 

   
   

Safeguarding reliability, affordability and public safety 

4. Include a dedicated objectives section in the Bill to explicitly guide ministerial discretion, prioritising consumer needs, reliability, quality, affordability, and public safety. 

   
   

Providers must be held to coherent and consistent minimum standards 

5. Strengthen the Minister’s powers to set minimum mobile service standards, benchmarks, and rules for a range of matters including the reliability, quality, and accessibility of mobile services. 

6. Align the Minister’s powers to set minimum standards, benchmarks, and rules requirements across the Bill to ensure consistency and integration.

7. Ensure standards, benchmarks, and rules are civil penalty provisions and accompanied by a robust compensation scheme for breaches.

   
   

Scrutiny, oversight and constraint on delegated legislation 

8. Amend the Bill and explanatory memorandum to require robust justification and clear constraints for any delegated powers to divide, expand, or delay the UOMO. 

9. Ensure significant changes to the UOMO are subject to increased oversight.

10. Ensure the Bill’s objectives section anchors all decisions regarding the UOMO.