Telstra's proposed SSU and Migration Plan variations16 Apr 2025

On 14 February 2025, Telstra submitted a request to vary its Structural Separation Undertaking and Migration Plan.

In summary, Telstra proposed to:

  • Reduce the reporting and disclosure requirements associated with both its Structural Separation Undertaking and Migration Plan, including simplified annual reporting arrangements.
  • Remove the requirements to have a Director of Equivalence, provide an Annual Equivalence Report and to provide updated documents about the Separation Compliance Program.
  • Clarify that certain reporting obligations have ceased to have effect after ending on the Designated Date.
  • Amend the Migration Plan to continue Telstra’s disconnection arrangement for the In-Train Order Premises.
  • Make several consequential amendments that clarify the variations outlined above.

Telstra was seeking to vary its reporting obligations given the significant reduction in remaining services it must migrate within the NBN fixed line footprint. Telstra advised that the estimated remaining services represented less than 1% of the total premises that have already been disconnected to date under the Migration Plan.

On 16 April 2025, the ACCC published a notice setting out the proposed variation of the Migration Plan and began a 28-day public consultation process, as required under s577BF(4)(a) of the Telecommunications Act 1997. The notice is available at: Notice of consultation on Telstra’s proposed variations to its Final Migration Plan ( PDF 59.42 KB )

Submissions were due by 5 pm (AEST) on 14 May 2025. The ACCC did not receive any submissions on Telstra’s proposed variations.

Supporting documents

Telstra's proposed variations and supporting documentation, as submitted on 14 February 2025, are provided below. Note that Telstra submitted an amended proposal on 17 June 2025, available at: Amended variation proposal for SSU and Migration Plan

Legislative Framework

The Telecommunications Act 1997 provides the legislative framework for Telstra’s Structural Separation Undertaking and Migration Plan, including proposed amendments. 

In deciding whether to accept a variation to the Structural Separation Undertaking, the ACCC must have regard to:

  • the matters (if any) set out in a relevant instrument made by the Minister; and
  • such other matters (if any) as the ACCC considers relevant.

The ACCC must accept a variation to the Migration Plan if it is satisfied the Migration Plan as varied complies with the Migration Plan Principles.