The TCP Code is being replaced. What it means for billing.

For two decades, consumer protection in Australian telco has run on an industry-authored code. Communications Alliance drafted it, the ACMA registered it, and enforcement ran through a warning-then-direction path that took a long time to bite.

That is changing. In October 2025 the ACMA rejected the industry's proposed replacement code. In March 2026 it announced it would make an enforceable industry standard under section 125 of the Telecommunications Act instead. The 2019 TCP Code remains in force until the new standard commences.

Why this is a billing problem

It is tempting to file consumer protection under customer service. But look at what the ACMA has signalled the standard will cover, and ask where the evidence actually lives.

• Responsible selling — whether a customer could afford the service they were sold. The evidence is the credit assessment, the plan, the spend history and what happened at the first missed payment.
• Credit and debt management — what was owed, what notice was given, what arrangements were offered before restriction or referral. All of it is billing-system state.
• Fair treatment of vulnerable consumers — whether hardship was identified, what was offered, and whether collections stopped when it was flagged.
• Advertising and information — whether what the customer was charged matches what they were told they would be charged.

None of those are answerable from a CRM note. They are answerable from a system that recorded the decision at the time it was made, with the inputs attached.

The gap most retailers have

The common pattern in Australian telco is a billing engine that rates and invoices, with consumer protection bolted on around it — a spreadsheet of hardship customers, a manual suppression list for collections, a quarterly compliance review that reconstructs what happened after the fact.

That arrangement survives a code administered by an industry body. It does not survive an enforceable standard, because the question stops being “can you show us your policy?” and becomes “show us every account where this applied, and what the system did.”

What good looks like

• Hardship status is a flag on the account that the collections process reads before it acts — not a list someone maintains alongside it.
• Spend management thresholds are enforced by the rating engine in near real time, not reported after the cycle closes.
• Every notice, restriction and payment arrangement is an event with a timestamp, a trigger and an actor, queryable as a set.
• Credit assessment inputs are retained against the sale, so an affordability question years later has an answer.
• Complaint handling carries TIO severity levels and escalation clocks in the workflow itself.

What to do before the standard commences

No commencement date has been announced, and there will be consultation before one is. That is the window, and it is the right time to answer one question honestly: if the regulator asked for a list of every account where a consumer protection obligation was triggered in the last 12 months, and what your systems did in each case, how long would it take to produce?

If the answer involves exporting to Excel and someone's institutional memory, the compliance work is really a systems project — and it is cheaper to start it now than under a direction.