1. Regulatory focus
The Australian Competition and Consumer Commission proposes an A2P SMS record-keeping regime covering wholesale services supplied by mobile network operators to aggregators or A2P retail providers, as well as A2P termination services. The first reference period runs from August 1 to October 31, 2026, with reports proposed by November 21. Future periods would end on January 31 and July 31 each year. Records would need to be retained for at least two years and include wholesale customers, on-net and off-net delivery, pricing, and commercial arrangements.
2. Business impact
This is not a consumer-facing content ban; it is a transparency measure for the A2P wholesale market. Carriers and major messaging providers may face reporting gaps if billing, routing, customer-management, and supplier systems cannot reconstruct traffic volumes, unit prices, and delivery relationships for each reference period. For CPaaS providers and cross-border aggregators, wholesale customer identity, destination network, and resale paths may become auditable commercial records, especially during pricing disputes or supplier reviews.
3. Operating recommendations
Build an A2P data dictionary by reference period, covering message volumes, on-net and off-net delivery, customer type, destination carrier, wholesale price, discounts, and resale relationships. For cross-border traffic, retain upstream provider details, routing changes, pricing versions, and not only final delivery reports. Before November 21, 2026, complete the first-period reconciliation, investigate anomalies, and confirm retention controls. The two-year retention period should be reflected in supplier contracts and internal deletion schedules.