Mobile coverage is going universal – even if the technology to deliver it isn't here yet. In October, the Universal Outdoor Mobile Obligation (UOMO) became law, promising voice and SMS coverage outdoors almost anywhere in Australia, from the outback to the coast, with the stated aim of improving public safety via connectivity.
The UOMO requires Telstra, Optus and TPG to ensure that mobile voice and SMS coverage is reasonably available outdoors to all people in Australia on an equitable basis, even though the technology to support it is not yet in place.
The legislation goes further than the existing Universal Service Obligation and requires the Minister to introduce new performance and reliability standards for terrestrial mobile services. It also allows the Minister to make other standards for non-terrestrial mobile services – e.g. standards about reliability of a mobile telecommunications service and the quality of voice calls.
In this alert we explain the key elements of the new regime and what it means for the key players in this space – mobile network operators (MNOs), LEO satellite (LEOSat) operators, carriage service providers (CSPs) and mobile virtual network operators (MVNOs).
What should you do now?
PUOMPs (currently Telstra, Optus and TPG): map your current coverage gaps against the outdoor coverage area and test your direct-to-device (D2D) arrangements against a 1 December 2027 start.
Other carriers and carriage service providers of mobile services (including MVNOs): you are not default PUOMPs. However, the mandatory terrestrial mobile standards will apply to you once implemented. Any general mobile standards, benchmarks and rules the Minister decides to make can apply to you from commencement.
LEOSat operators: consider what wholesale arrangements PUOMPs may need to enable them to comply with the UOMO.
All: watch for the ‘reasonably available’ instrument to better understand what it means to ensure that mobile coverage is ‘reasonably available’ and any change to the default day.
Key features of the UOMO and its impact
The Federal Government announced the UOMO in February 2025, responding to long-held concerns about mobile coverage gaps in regional and remote areas.[1] The UOMO will expand outdoor mobile coverage with the stated aim of improving public safety by helping people in remote areas reach emergency services and stay connected.[2] The Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Act 2026 (Cth) (UOMO Act) amends the Telecommunications (Consumer Protection and Service Standards) Act 1999 (Cth) (TCPSS Act), the Telecommunications Act 1997 (Cth) (Telecommunications Act) and the Competition and Consumer Act 2010 (Cth) to introduce the UOMO.
The key elements of the UOMO are:
- A new coverage obligation. From 1 December 2027 (unless the Minister moves that date), Australian mobile network operators Telstra, Optus and TPG must ensure that voice and SMS coverage is reasonably available outdoors to all people in Australia on an equitable basis, under the new UOMO.
- Satellite is the expected solution. The Federal Government expects operators will use D2D satellite technology to fill the gaps that terrestrial networks cannot reach.
- New players and services. The Minister can designate additional providers, including satellite-based providers, and add new services to the regime, such as data.
- New standards. The Minister must set performance and reliability standards for terrestrial mobile services for all carriers and carriage service providers, and may set standards, benchmarks and rules for all carriers and carriage service providers supplying mobile services.
- Temporary disaster roaming arrangements found adequate. On 29 October 2026, the Minister tabled a statement confirming that she is satisfied industry arrangements for temporary disaster roaming are sufficient. This means the Minister is not required to make a temporary disaster roaming determination to commence by 1 December 2026.
The Hon Michelle Rowland MP, Minister for Communications, ‘Albanese Labor Government building Australia’s mobile future’ (Media Release, 25 February 2025).
Revised Explanatory Memorandum, Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Bill 2026 (Explanatory Memorandum), p. 11.
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Act section references are to the TCPSS Act unless otherwise stated Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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The obligation (section 12F) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
The core obligation on Telstra, Optus and TPG is to ensure that mobile coverage is reasonably available outdoors to all people in Australia on an equitable basis. This includes supplying each kind of ‘designated mobile telecommunications service’ so that it is reasonably available outdoors throughout Australia. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Services covered (sections 5(2) and 8BB) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
The designated mobile telecommunications services under the UOMO are (to start with) voice calls and SMS that enable an end-user to communicate with other end-users. The need to communicate with other end-users helps characterise the two services as services that can be used for most general forms of communication, as they meet any-to-any connectivity expectations. The UOMO Act introduces the concept of a ‘mobile telecommunications service’ (MTS): a carriage service supplied to the public that an end-user can use while moving continuously between places, using customer equipment not in physical contact with the network. The Minister may add further kinds of MTS to the UOMO as technology evolves. Unlike a ‘public mobile telecommunications service’ (PMTS), an MTS does not depend on intercell hand-over functions. This means services delivered over D2D satellite platforms, which may lack those functions, are captured. Private networks, such as those serving a mine site or a farm, are not. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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‘Outdoors’ and ‘reasonably available’ (sections 5(2), 8D, 12F and 12H) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
The UOMO extends to all of Australia, including Christmas Island and the Cocos (Keeling) Islands. The Australian Radio Quiet Zone in Western Australia is excluded by default, and the Minister may exclude other areas.[3] ‘Outdoors’ excludes being in a building, vehicle, aircraft or vessel, or underground or underwater, reflecting (broadly) the current limits of D2D technology.[4] This is not a guarantee of coverage everywhere, at all times. The Explanatory Memorandum recognises that coverage may be unavailable due to technical limitations, outages, wholesale interruptions or incompatible handsets or plans.[5] The Minister may, by legislative instrument, determine circumstances in which no obligation arises, and matters that must, or must not, be considered in deciding whether coverage is ‘reasonably available’. The Government intends to consider such an instrument before 1 December 2027.[6] By analogy, the Telecommunications Universal Service Obligation (Standard Telephone Service – Requirements and Circumstances) Determination 2023 (USO Determination) provides that the obligation to supply a standard telephone service does not arise, for example, where the request is reasonably believed to be fraudulent, or a reasonable offer has been refused.[7] The ‘reasonably available’ test for the UOMO would be expected to pick up those basic limitations, as well as others specific to the characteristics of the UOMO. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Who is bound (sections 12G, 12J, 12K, 12L and 12M) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
From the default day of 1 December 2027 (unless the Minister changes the date), Telstra Limited, Optus Mobile Pty Limited and TPG Telecom Limited are taken to be ‘primary universal outdoor mobile providers’ (PUOMPs) and will be required to ensure that mobile coverage is reasonably available outdoors to all people in Australia on an equitable basis. The Minister may designate additional or different carriers or carriage service providers as PUOMPs for particular obligations and areas, but must ensure that, from the default day, every point in the coverage area is covered by at least one PUOMP. This leaves the door open to the Minister designating satellite-based providers as the PUOMP for a particular area. Where there are two or more PUOMPs in an area, each must comply individually. The UOMO is a retail obligation and does not itself mandate wholesale supply,[8] with the expectation that wholesale access can, if necessary, be dealt with under the declared services regime under Part XIC of the Competition and Consumer Act 2010 (Cth). The Minister may also split the UOMO into separate obligations (for example, voice and SMS), which could be imposed on different providers, at different times or in different areas. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Notification requirements (sections 12N and 12P) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
A PUOMP that becomes aware it is likely to cease being able to fulfil a UOMO obligation must notify the Minister and the Australian Communications and Media Authority (ACMA) in writing. Notice must be given at least 12 months in advance where reasonably practicable. Otherwise, it must be given as soon as reasonably practicable, and no later than 10 business days after the provider ceases to be able to comply. Where a PUOMP is replaced or ceases to be a PUOMP, the ACMA may also direct it to notify its UOMO customers of the date it will cease to be a PUOMP, the identity of the new provider and other information the ACMA specifies. The Minister can formally determine that a person is a former provider for the purposes of this notification requirement. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Timing (section 12M) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
The UOMO Act commenced on 27 October 2026, but the UOMO obligations take effect on the default day of 1 December 2027, when Telstra, Optus and TPG are taken to be PUOMPs. After consulting Telstra, Optus and TPG and having regard to technical, wholesale and consumer matters, the Minister may bring this date forward, or postpone it by 12 months up to three times. Given compliance with the UOMO relies on D2D technology, the commencement of the UOMO obligations will need to align with the technical capability being available. Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Standards, benchmarks and rules (sections 12Q to 12T and 125B to 125E; section 506A of the Telecommunications Act) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
Mandatory standards The Minister must determine standards to be complied with by carriers and carriage service providers relating to the performance and reliability of MTS supplied using terrestrial mobile networks. The MTS standards that the Minister must make must be made within three months after the ACCC publishes its final report for its mobile services inquiry.[9] In making these MTS standards, the Minister must have regard to the inquiry’s findings and undertake consultation. Discretionary standards The Minister may set standards, benchmarks and rules for PUOMPs in relation to the UOMO about matters such as price, reliability, call and SMS performance, fault rectification, congestion and customer information (PUOMP Standards). The PUOMP Standards can apply to terrestrial and non-terrestrial mobile services and can be made at any time. In addition, the Minister may determine standards, benchmarks and rules to be complied with by carriers and carriage service providers (not just PUOMPs) in relation to ‘mobile telecommunications services’ (see description of MTS above). Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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Temporary Disaster Roaming (section 158A) Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
On 29 October 2026, the Minister declared herself satisfied with the telecommunications industry’s temporary disaster roaming arrangements (contained in private agreements entered into by the MNOs) ahead of the 2026-27 high-risk weather season. Had the Minister found the arrangements insufficient by 31 October 2026, the Minister would have been required to impose a temporary disaster roaming framework by 1 December 2026, obliging specified carriers and carriage service providers to give end-users access to their mobile networks during natural disasters.[10] Explanatory Memorandum, pp. 7, 25. Explanatory Memorandum, p. 22. Explanatory Memorandum, p. 19. Explanatory Memorandum, p. 6. USO Determination, s 7(1)(a). Explanatory Memorandum, p. 8. The third Coalition amendment to the UOMO Bill required the Minister to ask the ACCC to consider, in its mobile services inquiry, the benefits to consumers and the impacts on investment and competition of declaring a domestic mobile roaming service. The Hon Anika Wells, Minister for Communications, ‘Temporary Disaster Roaming Industry Arrangements’ (Statement, 29 October 2026). |
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