Summary

  • ACMA's July consultation would narrow the rule that lets successive phones in one unchanged model rely on the first unit's test against an older air-interface standard. New models would start with the 2025 standards; existing models would have a proposed six- or twelve-month transition.
  • A later change to the emergency-call access standard, AS/CA S042.1:2025, would require testing for phones still being supplied after a transition. ACMA also proposes keeping compliance records for seven years after last supply, up from two.

A phone model can outlive the test that admitted it to the market. Australia's ACMA consultation paper describes the current arrangement: identical phones from one manufacturer or importer can form a class, and later units may rely on the original unit's compliance with an older industry standard if the model has not been materially modified. That is efficient for mass production. It is awkward when the part of the standard governing emergency calls moves on while the model remains on sale.

ACMA proposes two cuts to that inheritance. A model first made, materially modified or imported after the proposed 2026 Air Interface Standard starts would generally have to meet AS/CA S042.1:2025, plus the applicable 2025 3G/4G and 5G parts. Models already in the supply chain would have either six or twelve months to shift to the 2025 editions; ACMA asked consultees which period to choose. After that window, a manufacturer or importer could no longer use a pre-2025 first-unit test to supply another handset of the same model.

The second cut keeps operating after the initial switch. If AS/CA S042.1:2025 is amended or replaced, a phone continuing to enter the market would need to meet the new emergency-call requirements after a transition even when the model itself is unchanged. ACMA's draft instrument sketches a six-month transition for a change affecting S042.1 and twelve months for other mobile-phone standard changes. The paper still asks whether six or twelve months is the right period. The point of the split is concrete: an unchanged product line would no longer be an indefinite passport to an obsolete emergency-call test.

The record trail would last longer too. ACMA proposes that manufacturers and importers keep the relevant compliance documentation for seven years after the final Australian supply of an item or class, rather than two. That proposal covers customer equipment and cabling under the labelling notice, broader than the mobile-phone grandfathering change. An investigation into a device still in use would have a better chance of finding the test behind its label.

ACMA links the consultation to questions raised after the 18 September 2025 Optus outage about durable access to Triple Zero. It also states the boundary of its present powers. Regulation of a phone's performance after supply, or a live register tracking software updates and device status, would need legislative change. This proposal acts at the point of manufacture, import and continued supply. Its consultation page closed on 17 September and remains under review. No final transition period or enacted 2026 standard is shown there.