If your IT provider sells you phone services on their own invoice, they are almost certainly a carriage service provider under the Telecommunications Act 1997, and that means they carry consumer protection obligations enforceable by the ACMA. Most Melbourne IT companies that resell voice have never checked whether they meet them. That is a fair question to ask before you sign, because the obligations exist to protect you.
A carriage service provider, or CSP, is a business that supplies a telecommunications service to the public. Reselling a phone service in your own name, on your own invoice, to your own customers is supplying a carriage service, whether you own any network equipment or not.
Selling the phone system is not the same as selling the phone service
There is a line here that matters, and most buyers have never seen it drawn.
If a provider installs 3CX for you, configures Microsoft Teams Phone, or racks handsets, and you hold the SIP trunk contract directly with a carrier, that provider is selling you professional services and software. They are an integrator. The carrier is your CSP, and the carrier carries the regulatory obligations.
If the same provider sells you the trunk, the numbers and the call charges on their own invoice, and you never see the underlying carrier’s name, they are reselling a carriage service. They are your CSP. The obligations are theirs.
Both models are legitimate. The problem is that a lot of providers operate the second model while assuming they are in the first, and the customer cannot tell which one they are in by looking at the quote. Check the invoice. If your call charges appear on your IT provider’s invoice, ask the question in the last section of this post.
What the TCP Code actually requires
The Telecommunications Consumer Protections Code, currently C628:2019 incorporating Variation No.1/2022, is the main instrument. The ACMA describes it as containing rules for telecommunications providers covering how providers communicate with and deal with customers, what they can say in advertising and sales information, handling bills and disputes, the ways customers can pay, how credit is assessed for new customers, and how customers are helped to switch providers. It applies to carriage service providers and it is enforceable by the ACMA.
In practical terms, here is what a compliant provider has to have in place.
Critical Information Summaries. For every telecommunications product or service offered, the provider must produce a short standardised document setting out what the service is, what it costs, the minimum term, early termination charges and how to get help. It has to be on their website and given to the customer at defined points in the sales process. This is the single most visible compliance artefact. If your provider sells you voice and cannot produce a CIS for the service you bought, that is your answer.
Clear presentation of fees and charges. The code governs how prices, inclusions, exclusions and minimum monthly charges are presented in advertising and in the sales conversation, so a customer can compare offers on the same basis.
Complaints handling. There must be a documented complaints handling process, published, accessible, with defined acknowledgment and resolution timeframes and an escalation path. The ACMA has already lifted this out of the code and into the Telecommunications (Consumer Complaints Handling) Industry Standard 2018, which is direct regulation rather than an industry code.
Financial hardship. The Telecommunications (Financial Hardship) Industry Standard 2024 requires providers to have and promote an accessible financial hardship policy, to take reasonable steps to identify customers who may be experiencing hardship, and to work out whether a customer is in hardship before disconnecting their service. This applies to small business customers, not only residential.
Domestic, family and sexual violence. The Telecommunications (Domestic, Family and Sexual Violence Consumer Protections) Industry Standard 2025 is another safeguard the ACMA has already lifted out of the code and into direct regulation. A first set of obligations applied to every provider from 1 July 2025, covering reversing disconnections on an urgent safety-related request, not making an affected customer deal with an alleged perpetrator, and publishing what support is available. The remaining obligations applied from 1 January 2026 for providers with 30,000 or more services in operation and from 1 April 2026 for providers under that threshold, which is where a reselling IT provider sits. The ACMA has adopted the same definition of consumer used in the hardship standard, so small business and not-for-profit customers are in scope.
Credit assessment and billing. The code sets rules on credit assessment for new customers, on billing accuracy, on itemisation and on debt collection conduct.
Outages and keeping customers informed. The Telecommunications (Customer Communications for Outages) Industry Standard 2024 took effect on 31 December 2024 and sets obligations around informing customers during major network outages, including publishing information on the provider’s website and giving regular updates. The heaviest obligations in that standard are triggered at major outage scale, which is a carrier-level event, but the underlying expectation, that a provider tells its customers what has happened and when it will be fixed, applies to everyone selling voice.
Membership of the Telecommunications Industry Ombudsman. Under sections 128 and 132 of the Telecommunications (Consumer Protection and Service Standards) Act 1999, carriers and eligible carriage service providers must join and comply with the TIO scheme. The ACMA is specific about who that catches: you must join if you supply, or arrange for the supply of, a standard telephone service to residential or small business customers, a public mobile telecommunication service, or access to the internet. Exemptions exist but must be granted by the ACMA case by case, and the ACMA publishes the ones it has declared.
This is a legal requirement, not a badge, and what it buys you is concrete. Once you have complained to your provider and got nowhere, you can take the dispute to the TIO, which is an independent, industry-funded dispute resolution scheme that is free to the customer and handles complaints from individuals and small businesses. It is external dispute resolution, so the provider’s own complaints process has to be tried first. The TIO also publishes a public register of its members, which means membership is a claim you can check for yourself in about a minute rather than a line on a capability statement. If your IT provider resells voice and is not a TIO member, you do not have that path.
The ACMA is replacing the code with an enforceable standard
This is current and it changes the risk profile for any provider reselling voice.
On 27 March 2026 the ACMA announced it will determine an enforceable industry standard under section 125 of the Telecommunications Act 1997 to replace the industry-developed TCP Code. ACMA Chair Nerida O’Loughlin said the decision followed a development and consultation process commenced in 2023 by industry through the Australian Telecommunications Alliance and its predecessor, and that the ACMA still does not have before it a code capable of registration.
The ACMA’s stated reasoning was that consumer reliance on telecommunications is far greater than when the current code was made in 2019, and that network outages, Triple Zero unavailability, shortcomings in the 3G shutdown process and significant issues with responsible selling had undermined confidence in the sector. Moving the remaining protections into direct regulation means, in the ACMA’s words, that obligations are clear and backed by stronger and more immediately available enforcement powers for the regulator.
Two things follow for you as a buyer.
First, the 2019 code has not gone anywhere. The ACMA has confirmed the existing 2019 TCP Code remains in force until the new standard commences, at which point the code ceases to be registered. C628:2019 incorporating Variation No.1/2022 is the current instrument today. Anyone telling you the TCP Code no longer matters is wrong.
Second, the enforcement environment is tightening rather than loosening. The section 125 process includes public consultation before the standard is determined. Separately, the Telecommunications Amendment (Enhancing Consumer Safeguards) Bill 2025 establishes a carriage service provider registration scheme requiring CSPs to register with the ACMA in order to supply carriage services, prohibits carriers and wholesale CSPs from supplying an unregistered CSP, and lets the ACMA revoke a registration where a provider poses unacceptable risk to consumers.
There is no commencement date to put in your diary, and any provider who quotes you one is guessing. The Bill is not yet law. An earlier version was introduced in February 2025 and lapsed when Parliament was dissolved for the election. The current Bill was introduced on 28 August 2025, passed the House of Representatives on 14 May 2026, and is before the Senate. Even once it passes, commencement is a sequence rather than a date: the Parliamentary Library’s bills digest records that Schedule 1, which contains the registration scheme, commences on the earlier of a day fixed by proclamation or 12 months after Royal Assent, and that the registration obligations then apply only after a further six months. The other three schedules, covering directly enforceable industry codes and higher penalties, commence the day after Royal Assent.
Track the proclamation rather than the passage. The practical effect of the registration scheme, once it is running, is that a provider reselling voice without registering will find their upstream wholesale supply cut off. That is not a fine. That is your phone service stopping.
Why this is your problem and not just theirs
Regulatory obligations sit with the provider. The consequences of a provider not meeting them land on you.
If your provider is not a TIO member, a billing dispute you cannot resolve has no independent umpire and your only path is a commercial one. If they cannot produce a Critical Information Summary, you have no standardised statement of what you bought, which makes comparison at renewal almost impossible and makes early termination charges a surprise. If they have no documented complaints process, escalation is whoever answers the phone. If they have not thought about the hardship standard, the first time a customer of theirs hits genuine financial difficulty is the first time anyone reads it.
And if a provider is reselling carriage services while unregistered, once the registration scheme is in force, the risk you are carrying is that your phone numbers sit behind a supply arrangement that can be stopped.
The questions to ask, in order
Put these to any IT provider quoting you voice. The answers take five minutes and tell you a great deal.
- Are my call charges on your invoice, or on a carrier’s invoice? If yours, you are my carriage service provider. Confirm that in writing.
- Are you a member of the Telecommunications Industry Ombudsman scheme? What is your member name, so I can check the TIO service provider directory myself?
- Show me the Critical Information Summary for the exact voice service you are quoting.
- Show me your published complaints handling policy and the timeframes in it.
- Show me your financial hardship policy.
- When the new ACMA industry standard commences, what changes for me, and who at your end is tracking it?
- Whose numbers are these? If we part company, what is your process for porting them out, and what does it cost?
A provider who has done the work will answer all seven without hesitation and will probably send you the documents before the meeting ends. A provider who has not will change the subject to features.
The five documents a compliant provider can send you the same day
Turn those questions into a document request and the answers get much harder to fudge. A provider meeting its carriage service provider obligations already holds all five of these, because they are the paperwork that follows from selling a regulated service. Ask for them in writing.
- The Critical Information Summary for the exact service on your quote, published on their website as well as sent to you.
- A published complaints handling policy with acknowledgment and resolution timeframes and a named escalation path, consistent with the Telecommunications (Consumer Complaints Handling) Industry Standard 2018.
- A financial hardship policy that is easy to find on their site and covers small business customers, consistent with the Telecommunications (Financial Hardship) Industry Standard 2024.
- Their TIO member name, so you can check the Telecommunications Industry Ombudsman’s own listing yourself rather than take their word for it.
- A written statement of who holds your numbers, what porting them out involves, how long it takes and what it costs.
How long each takes to arrive is the real test. Documents that come back the same day exist because someone maintains them. Documents that take a fortnight are being written for you.
Our own answers, since it would be poor form to set a test we have not sat: TechAssist complies with the TCP Code, is a member of the Telecommunications Industry Ombudsman scheme, and tracks the ACMA’s current and forthcoming policy changes, including the move to an enforceable industry standard under section 125.
That is the shape of the answer you should be getting from anyone who puts call charges on your invoice. It is deliberately narrow. It is a statement about compliance and membership, and you can verify the membership half yourself in the TIO’s public register without asking us anything. Treat any provider who answers the seven questions with something broader and vaguer than that as having answered a different question.
The principle underneath it is simple. Voice is a regulated service, not an accessory to a managed IT contract. If a provider is going to put call charges on their invoice, they should be able to produce the same compliance artefacts a carrier can, and they should hold the documentation set a provider should already hold for everything else they run for you as well. Ask us the same seven questions you ask everybody else.
None of this decides which platform you should buy. That is a separate question, covered in choosing between hosted PBX, Teams Phone and 3CX, and it sits on top of VoIP for Australian business and the underlying internet service. What it decides is who you should be willing to buy from.
Send your current voice provider the seven questions above and see what comes back. If you want a second opinion on the answers, or you want us to answer them ourselves, call TechAssist on 1300 028 324 or use https://techassist.au/contact/. We will do it on a call, not in a proposal.
