Submission to the Australian Competition and Consumer Commission’s consultation on telecommunications infrastructure assets record keeping rules

In short, Commpete supports the ACCC’s proposal to amend the Record Keeping Rules (RKRs) to require mobile network operators (MNOs) to report details of any Commonwealth or state government co-funding of mobile sites. However, we believe this reporting obligation should be extended to require MNOs to indicate whether a co-funded site is included in any wholesale mobile coverage supplied to mobile virtual network operators (MVNOs). This could be achieved with a simple yes/no statement in the template report, with exception reporting if a co-funded site happens to be included in some wholesale offers but not all.