Before the start of the Structural Separation Undertaking (SSU), Telstra was subject to an operational separation framework. This was intended to promote equivalence between Telstra wholesale and retail customers.
We have previously publicly stated that the operational separation regime, and our limited role in investigating and reporting matters to the Minister, was largely ineffective in addressing Telstra’s ability and incentive to discriminate against its competitors.
See page 22 of Explanatory Memorandum to the Telecommunications Legislation Amendment (Competition and Consumer Safeguards) Bill 2010.