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Systemic issues

We drive industry improvement by identifying, investigating and helping to resolve systemic issues. By sharing our insights and working with telecommunications providers to improve their practices, we achieve better outcomes for consumers and the industry.

What is a systemic issue?

A systemic issue is one that has or is likely to have a negative effect on a number of consumers or occupiers or a particular type of consumer or occupier, including about:

  • telecommunications provider’s systems, policies, processes or practices

  • repeated conduct by a telecommunications provider that indicates potential non-compliance with the law, regulatory requirements, or good industry practice

  • widespread issues driving complaints, which may arise from general industry practices, gaps in consumer awareness, or the broader regulatory and telecommunications operating landscape.

How we identify and assess possible systemic issues

We identify possible systemic issues through handling complaints, analysing complaint trends and receiving information from other organisations.

These include telecommunications providers, consumer groups, the media and regulators. We assess possible systemic issues by looking at any relevant complaints, including a change in complaint patterns or multiple complaints about the same issue.

We also consider the impact on consumers (including disproportionate impact on consumers experiencing vulnerability) and laws, codes and industry practice.

If we decide to investigate a possible systemic issue, we notify the relevant telecommunications provider.

Systemic Issue Guidelines

Systemic issue guidelines explain how we identify and investigate problems that may affect many consumers, and how we work with providers to fix them and improve industry practices.

How we notify a provider

We notify a provider in writing, by:

  • explaining our observations of the impact on consumers

  • specifying any relevant complaints we have identified

  • asking the provider for its response to our questions

How we work towards resolution

  1. We work with the service provider to address a systemic issue, often reaching an agreed resolution through consultation and negotiation.

  2. We will seek to understand the issue and may suggest improvements or remedial actions. We may ask providers to commit to timeframes for any agreed actions.

What providers must do

  • Work with us

    Providers must cooperate with our investigations and provide information or documents with the timeframes we specify.

  • Investigate problems

    Providers must try to resolve the main cause of a problem where a complaint indicates a broader problem or systemic issue.

What happens if a systemic issue cannot be resolved by agreement

If a systemic issue cannot be resolved by agreement, we can:

  • make a systemic investigation recommendation that a provider does or refrains from doing anything necessary to address a systemic issue, or
  • refer the systemic issue to relevant regulators, such as the ACMA, the ACCC, the OAIC or another appropriate body.

What else we do to promote industry improvement

  • Publishing reports

    In addition to investigating systemic issues about individual providers, we publish reports on widespread issues driving complaints. These reports serve the dual purpose of recommending improvements in industry practice and advising consumers on how they can avoid common issues.

    Read our reports about Publishing reports
  • Sharing information

    We may share information with regulators to address systemic issues, reduce complaints and contribute to industry improvement. We may also share information with government bodies, telecommunications providers, and community and industry groups to promote good practice and industry improvement.

    See our policy submissions about Sharing information