Other A2P SMS regulations

Australia A2P SMS Reporting Starts

For carriers, aggregators, and CPaaS providers serving Australian OTP, delivery, appointment, and marketing traffic, regulatory attention is moving beyond sender identity toward wholesale A2P SMS pricing and transaction visibility. The ACCC’s proposed record-keeping rules would require covered providers to retain records for at least two years. The first reporting period ends on October 31, 2026, with submissions proposed by November 21, 2026.

Published:11/01/2026 Updated:11/01/2026

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.

Frequently Asked Questions

We are a cross-border CPaaS provider, not an Australian carrier. Do we still need to prepare reporting data?
The direct obligation is aimed mainly at designated record keepers, but CPaaS providers and aggregators may need to support carriers as wholesale customers or data suppliers. Prepare exportable records by customer, destination network, delivery type, and pricing version so carrier submissions can be reconciled with your own invoices and routing data.
The first reference period has ended. What should we check first?
Freeze the August 1–October 31, 2026 period first. Reconcile totals across billing, routing, and customer contracts, then separate on-net, off-net, and termination activity. Create an exception log for unidentified wholesale customers, temporary discounts, and routing changes, with evidence explaining each adjustment rather than relying only on aggregated figures.
Could the two-year retention period conflict with our existing deletion policy?
Potentially. Separate regulatory transaction fields from message content and personal data. Retain the required pricing, delivery, and commercial records for two years, while deleting unnecessary message content or personal data under your privacy schedule. Document field-level exceptions, expiry dates, and deletion logs so compliance does not become a reason to retain complete SMS content indefinitely.
This article is for informational purposes only and does not constitute legal advice.

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