Review of the International Roaming Standard | ACMA

Review of the International Roaming Standard

Consultation closes: 11 September 2018

IFC: 30/2018 .

Outcome of this consultation

Update on review 

The ACMA has completed a review of the International Mobile Roaming Standard (IMR Standard).

The review found that the IMR Standard has been effective in reducing ‘bill shock’, with the number of complaints about IMR failing significantly. However, Telecommunications Industry Ombudsman (TIO) data indicates complaints about IMR services have risen in recent years. While complaint numbers are still relatively low, the charges in dispute can be high, indicating that risks to consumers remain.

The review identified there was a need to retain IMR regulation, but that there were areas that could be improved to make regulation more flexible in light of changes to mobile phone use overseas. For example, the review concluded that it would be appropriate to allow providers flexibility in the wording used to advise consumers about maximum charges for IMR services, and how the information is delivered. The review also concluded that mobile network operators and mobile virtual network operators (resellers) should continue to provide information to consumers on their arrival in another country. The full report can be found here.

The Minister for Communications and the Arts, Mitch Fifield, has also agreed to an ACMA proposal to change the form of regulation from an industry standard to a service provider determination with a similar but more flexible set of rules. The change would allow the ACMA to more easily update the instrument.

The ACMA is liaising with the Department of Communications and the Arts on next steps and anticipates releasing a draft service provider determination for public consultation within the next few months.

Submissions

The ACMA received nine submissions to this consultation, of which one was made in-confidence. The public submissions can be accessed from the ‘Other submissions received’ tab in the right hand side index box.

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Background

The ACMA is seeking stakeholder and community views about the efficiency and effectiveness of the Telecommunications (International Mobile Roaming) Industry Standard 2013 (the IMR Standard). These views will assist the ACMA in its review of the IMR Standard, which is required under Clause 11 of the Standard.

International mobile roaming (IMR) occurs when consumers use telephone or internet services overseas via their Australian mobile service provider. Consumers keep the same SIM card in their mobile device, and access to overseas mobile networks is available through agreements linking their Australian mobile service provider with overseas mobile network owners.

Charges for IMR activities like voice calling, SMS, internet browsing and video streaming can be much higher than charges for the same activities in Australia. The significant differences between the domestic charges and overseas charges can lead to ‘bill shock’, where customers receive unexpectedly high bills for IMR services. In 2012–13, there were 1,926 complaints to the Telecommunications Industry Ombudsman (TIO) about IMR, with a median dispute amount of $1,200.

For this reason, in June 2013, the (then) Minister for Broadband, Communications and the Digital Economy directed the ACMA to make the IMR Standard. The Standard was intended to protect consumers from unexpected high bills during an overseas trip by allowing them to monitor, track and, where necessary, alter their use of their mobile telecommunication services to better manage their spending.

The IMR Standard

The IMR Standard places obligations on providers of IMR services, which currently differ depending on whether the provider is a mobile network operator (MNO)— Telstra, Optus and Vodafone—or a mobile virtual network operator (MVNO), which utilises an MNO’s mobile network.

Mobile network operators

Obligations on MNOs commenced in 2013. The obligations include giving consumers information and tools that minimise the risk of bill shock from IMR. These include:

  • SMS notification to customers when they arrive at an overseas destination:
    • warning that the customer has activated IMR and that significantly higher charges may apply
      Example: Warning – you have activated your mobile device overseas. Significantly higher charges may apply. There may be delays in receiving usage data and alerts.
    • giving the maximum charging information for IMR services for the country where the service is activated (for example, call and SMS rates to and from Australia and within the country and cost per megabyte of data downloaded)
    • giving information about how to ‘opt out’ of IMR at any time, including from an overseas location. If requested, the service must be cancelled as soon as practicable by the service provider and within 24 hours.
      Example: Cost 1 min call to Aus=$[cost in dollars and cents], 1 min call within [country]=$[cost in dollars and cents], receipt of 1 minute call=$[cost in dollars and cents], SMS to Australia=$[cost in dollars and cents], SMS within [country]=$[cost in dollars and cents], receipt of SMS=$[cost in dollars and cents], 1mb data=$[cost in dollars and cents]. To cease all services while overseas [description of opt-out mechanism]
  • offering at least one spend management tool that allows the customer to obtain current estimates about their level of IMR usage
  • sending SMS spend management alerts to customers using IMR services:
    • when the customer has used increments of $100 worth of data (for customers using post-paid plans and automatic direct debit pre-paid plans)
    • when the customer reaches 50 per cent, 85 per cent and 100 per cent of the included value in a purchased travel pack. When 100 per cent of included value is reached, the maximum charge information must also be conveyed by SMS message.
      Example 1: We estimate you’ve used $100 worth of data since [date]. Charges will continue to apply for data usage. To monitor your usage, please visit [website] or dial [phone number] at no additional cost.
      Example 2: We estimate you’ve used 50% of your [included value travel pack] allowance. To monitor your usage, please visit [website] or dial [phone number] at no additional cost.

All these measures apply to the MNOs— Telstra, Optus and Vodafone.

Delayed obligations on MVNOs

MVNOs provide services using the network of one of the three MNOs. Customers of MVNOs receive a warning message from an MNO when they arrive overseas, notifying them they have activated mobile roaming and that significantly higher charges may apply.

A staggered approach to the introduction of full obligations on MVNOs was adopted when the Standard was made in 2013. A delay in the application of some provisions to MVNOs was intended to allow these providers time to put appropriate systems in place.

Currently, MVNOs must provide customers with:

  • pre-travel information at the time they are provided with an IMR service:
    • including details about maximum charges in the top 10 destination countries for Australians
    • explaining how the customer can request maximum charge information for other countries
    • detailing the IMR spend-management tools available
    • setting out how to decline IMR services from overseas
  • an ACMA fact sheet on alternatives to IMR services.

In 2016, the Standard was varied to further delay commencement of full obligations for MVNOs. The intention was to postpone those obligations until after the 2018 review, to consider the extension of the obligations to resellers in light of consumer experiences.

Under the present IMR Standard, the requirement to provide pre-departure information would be replaced by the requirement for MVNOs to provide the full suite of protections from 1 January 2019.

Key focus areas for review

The level of consumer complaints to the TIO about IMR charges fell significantly after the IMR Standard was introduced. IMR-related complaints dropped by 35 per cent, from 1,926 in 2012–13 to 1,253 in 2013–14. By 2015–16, IMR-related complaints had dropped again to 608. While more recent TIO data indicates that IMR complaints have since risen, the numbers remain low as a proportion of total complaints. Currently, there appears to be little evidence of the consumer harms that the IMR Standard is designed to address.

Since the introduction of the IMR Standard, there have been a number of changes in the market, which may impact how consumers use mobile devices when travelling overseas. These include:

  • specialised service offerings for consumers, such as international roaming supplements or packages
  • free public internet access has become more widely available overseas, which reduces the need for consumers to rely on IMR services
  • alternatives to conventional messaging and voice services have emerged, providing potentially cheaper options for making voice calls and sending messages.

The ACMA is keen to understand whether the IMR Standard has been, and remains, an efficient and effective safeguard. The ACMA welcomes comment on any aspect of the IMR Standard and its operation, and is particularly interested in views on:

  • whether environmental and market changes suggest that the IMR Standard should be changed
  • the effectiveness of consumer notifications required under the Standard
  • the mode of delivery for consumer notifications
  • the application of obligations in the IMR Standard to MVNOs.

Issues for comment

Issue 1—Changes to IMR services

Do you have a view on the changes to the market for IMR services? Does the IMR Standard continue to offer appropriate protections to consumers?

Does the form and scope of the IMR Standard continue to reflect the environment in which IMR services are delivered? Has the Standard kept up with changes to these services?

Issue 2—Consumer notifications

Do you have a view on the notification requirements in the IMR Standard? For example, is the wording and detail in consumer notifications effective?

Does the wording and content of alerts remain appropriate in light of new products on the market, such as roaming bundles?

Is the current system of country-based rate alerts effective, or should an alert be required when there is a change in charging rate?

Are the usage alerts consumers receive when overseas accurate and timely enough to prevent bill shock?

Issue 3—Delivery of information provided to consumers

Do you have a view about the effectiveness of SMS as the mode of delivery for consumer notifications? Is SMS the most effective mechanism to deliver consumer notifications at no cost to the customer?

Should the Standard allow for other modes of delivery for information and notifications, at no cost to the customer?

Issue 4—Obligations for mobile resellers
Are the obligations for MVNOs (mobile resellers) under the IMR Standard, due to come into effect in January 2019, still appropriate and fit for purpose?