Thank you, dear reader, for sticking with me for Hardcoded, a series on the emergency camp on functionality of mobile phones used in Australia, that is, their ability to dial emergency service numbers like 000 when their home telecom network is unavailable (I abbreviate that to ‘camp on’).
Having gone through the context, technicalities, fallout and regulatory landscape for this telecommunications policy fiasco, we are in the ‘Where to from here?’ phase. And in that phase, we’ve looked at the need for all phones to be network-agnostic with respect to dialling emergency services, as well as that for robust device testing regimes.
Today, we will be exploring the importance of telcos, OEMs and the state being on the same page with respect to the camp on capabilities of phones.
Some housekeeping to refresh our memories about key concepts and terms.
Housekeeping
In this series, I distinguish between:
61 ‘Updatable Models’—that Samsung said could be fixed through over-the-air firmware updates; and
10 ‘Hardcoded Models’—that Samsung said could not be fixed and thus required replacement.
Note also some keywords about dialling emergency services over here:
The general emergency service number is 000 (the one I focus on in Hardcoded), while 106 is the one for use with teletypewriters and 112 is an alternative number for mobile phone users, as per Telecommunications Act 1997 (Cth) s 466(2) (‘Telecommunications Act’) and Telecommunications Numbering Plan 2025 (Cth) s 20.
An ‘emergency call service’ handles calls to emergency service numbers and ensures that emergency services are dispatched when and where they are required (to summarise the definition in Telecommunications Act s 7). Our federal telecommunications regulator, the Australian Communications and Media Authority (‘ACMA’) oversees emergency call services in Australia as per part 8 of the Telecommunications (Consumer Protection and Service Standards) Act 1999 (Cth).
Also note the following key acronyms:
LTE = Long Term Evolution = A 4G telecommunications standard enabling wireless broadband communication for mobile devices at faster speeds than on 2G/3G networks.
eVoLTE = A configuration which allows your phone to make an emergency voice call on an LTE network. I’m borrowing from TPG Telecom’s use of ‘eVoLTE’ in this fashion, rather than the industry shorthand for ‘Enhanced/Evolved VoLTE’.
000 Inquiry = The Senate Environment and Communications References Committee’s inquiry into the September 2025 000 outage.
TPG = TPG Telecom, the company which used to be called ‘Vodafone Hutchison Australia’ but became part of the TPG telecommunications group by merger in 2020 and is listed on the ASX.
Registering Risk
A major issue which has cropped up in the wake of the 000 outage in September 2025 and the 000 Inquiry is information-sharing between phone manufacturers, telcos and OEMs with respect to phones that can/can’t dial 000 (or any emergency service numbers for that matter). Namely, the need for a register of such phones, whether the register should be made public and who should operate this register (ie the government through the ACMA versus industry).
In Testing, I touched on the ‘Australian Telecommunications Alliance Device End-to-End Service Testing Group’ (‘DETEST Group’), which has Apple, Certification Body Australia, Comtest Laboratories, Optus, Samsung, Telstra and TPG as members. (Please note that the Australian Telecommunications Alliance or ‘ATA’ is the peak body for the telecommunications industry here and its members include OEMs and telcos.)
One part of the DETEST Group’s terms of reference is nutting out a way forward for the Telecommunications (Emergency Call Service) Determination 2019 (Cth) (‘ECS Determination’, which I went through in Oversight) after the inquiry into the 2023 Optus network collapse (aka the Bean Review). This includes matters like (emphasis added):
developing a common approach to devices permitted to connect to Australian networks, such as the ‘future development of a proposed ACMA/government database’; and
testing of the camp on of phones, as well as sharing of technical data and test results, whether for devices (to be) supplied to our market or they’re grey market phones (devices from overseas that may not support the LTE/5G frequency bands allocated to telcos over here), ‘with a view to developing an industry database’ for 000 capabilities of phones in order to help telcos manage said capabilities.
The DETEST Group terms of reference say that this potential emergency calling capabilities database is ‘initially’ to be kept private, but that the group ‘will determine when this [database being made public] is appropriate’.
Which is weird because Samsung has a website (last updated 28 November 2025) where it lists Updatable and Hardcoded Models.
Weird also because the telcos themselves (via the submission of the ATA to the 000 Inquiry) want ‘mobile device suppliers to populate a public register of compliant (tested) devices sold in Australia’ (emphasis added), with such a register recommended to include declarations of conformity (required per product from the OEMs or importers under Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2025 (Cth) s 11 (‘TLN’)). They want ‘the ACMA or another appropriate government agency’ to run the register because of the ACMA’s oversight of the TLN framework and its running other key registers.
Furthermore, Samsung itself has recommended (via the testimony of Samsung Electronics Australia’s Head of Mobile Division, Eric Chou, to the 000 Inquiry) the creation of a register of all phones ‘brought into Australia’ with their declarations of conformity as ‘a very good first step’. Chou flagged the problem with tons of devices connecting to telco networks that haven’t been tested by telcos and Samsung because, eg, they’re grey market phones from overseas.
The Power of One. Ledger.
To zoom out a bit, decent regulation requires decent information. Indeed, Professor Julia Black, renowned scholar of regulatory theory, wrote that (emphasis added):
[R]egulation … may involve mechanisms of standard-setting, information-gathering and behaviour-modification.
In the present case, I agree with the telcos’ position, as expressed in the ATA’s submission, that the proposed public register of phones, their emergency calling capabilities and accompanying declarations of conformity will improve the TLN framework. Stakeholders need a single ledger about what phones are out there pinging Australian networks and whether they can actually access emergency call services, including camp on, as alluded to by Eric Chou in his testimony.
This will enable better compliance by telcos with their notification and blocking obligations under the ECS Determination pt 4. After all, they (carriage service providers, to be precise) are obliged to proactively scan their networks for, notify the owners of and then block phones that aren’t/are no longer configured to access ‘the emergency call service’ which I assume here to mean the one for 000 and 112. It certainly would help them better carry out these obligations if they could corroborate their own findings on the 000 capability of phones pinging their towers through such a register.
This register will also enable the OEMs to better clock which of and where their phones are being used. While it’s a given that grey market phones are a serious risk to stakeholder awareness of emergency calling—including camp on—capabilities, having a register available for the OEMs is vital so that they can more swiftly react to what’s happening with their handsets that are domestically supplied or even take pre-emptive action on the basis of their own testing procedures. After all, Samsung Australia had no idea that it had sold phones from the 71 problematic models to TPG until Telstra had raised the alarm, which would have been despite its arguably comprehensive sales and inventory management processes as a multinational OEM.
To build on that back-and-forth between OEMs and telcos, the importance of a register which tells those dialled into it (I apologise for nothing) specifically about phones’ ability to access emergency call services is underlined by the sort of data currently shared by an OEM like Samsung with telcos on request.
Let’s return to Eric Chou’s testimony (emphasis added):
With regard to TPG Vodafone [TPG], we [Samsung] provided them the TAC [Type Allocation Code]—the first eight digits of the unique identifier [International Mobile Equipment Identifier or ‘IMEI’] for the device—and also the software variant that they need to be on. That was the information that had been requested of Samsung, which we provided as requested.
Let’s face it: that data—whether it’s the TAC, the full IMEI or the software version—says very little, if at all, about camp on capabilities; let alone even the CSC (for Samsung phones) or carrier profile running on the given phone. An IMEI, for instance, basically tells you the brand and model. It doesn’t tell you if the handset is eVoLTE-capable or not.
Hence, it is not ideal if the TAC, IMEI and/or software version are the things being used by telcos to guide their compliance with blocking obligations under the ECS Determination. An instrument which, to borrow the words of Australian telecommunications expert, James Parker, makes the ‘telcos … judge, jury and execution[er]’ with respect to phones that ping their towers. Far from ideal when there was this warning in the Bean Review itself:
The carriers do not test with and/or across each other’s networks. While testing the camp on function on their own networks, even if covering all scenarios, the testing does not guarantee (as far as practicable) that calls will be picked up when a competitor’s network is unavailable.
As Parker also bemoaned in November 2024, perfectly functional eVoLTE-capable phones were being ‘[l]umped in with “incompatible” devices [and thus blocked by telcos] because the telcos have next to no visibility of what individual devices can make emergency calls over 4G’. That was, mind you, around a year before the co-regulatory device and network equipment testing regulatory instrument, C674:2025 Emergency Calling – Network and Mobile Phone Testing (‘Testing Code’), came in.
Parker’s findings in December 2025 suggested the issue to have worsened, especially in the absence of proper or even recent device testing from major telcos like Telstra or Optus (emphasis added):
Looks like that was entirely correct, they were relying on old test results and neither the telcos nor Samsung bothered to do even the most basic level of double checking and due-diligence.
Hence, if there is a register of the camp on capabilities of phones, certainly one as a consequence of the implementation of the Testing Code, it will at least make it harder for telcos to play funny buggers with compliance with device blocking obligations, including to pursue commercial interests via a form of forced obsolescence (which I will look at in the final piece of Hardcoded).
That would be by making it easier for them to identify which devices pinging their towers actually are configured to access emergency call services, such as the one for 000 and 112. To wit, this register is sorely needed in light of each of the telcos doing their own thing for identifying problematic phones, as per the testimony of Eric Chou to the 000 Inquiry.
I should add for sake of completeness that Chou testified about Samsung’s working with the telcos since late 2023 (leading up to the 3G shutdown over here) ‘to provide them with the information so that they’re able to identify the devices that need to be blacklisted on their respected [sic] network’). This included the provision of ‘information relevant to the identification of devices that needed to be either blocked or replaced in preparation for the closure’ to TPG by mid-2023. This was good, albeit not good enough. Oh, and we need more clarity about what this cooperation looked like.
Caveats
Of course, my views are subject to the caveats I listed in Testing. Declarations of conformity borne from existing testing procedures and paradigms are fallible. A more robust stance by the ACMA is required, as is regular, independent auditing of said declarations. Mate, how bad is it when your regulatees’ industry group complains in an official submission about a lack of independent auditing of phones and calls for ‘regular audits of a sample of devices in market’?
Furthermore, as per section 22(2) of the TLN, the declaration of conformity does not specify the software and firmware configuration of the phone with respect to camp on, rather what standards it has been assessed as compliant with. The proposed register must thus include specific data on those configurations and the actual testing reports, fast-tracking what the terms of reference for the DETEST Group foreshadow (though, they want an industry database for 000 camp on capabilities, which is to be private at first, as above).
The ACMA Must Step up
I believe that the ACMA should run this register. It is the telecom regulator and is in charge of emergency call services like that for 000 (as flagged above).
And that register must be made public, lest we get ‘secrecy dressed up as accountability’ (I note that Senator Melissa McIntosh was referring to a government ‘proposal to allow telcos to operate their own outage databases’, not a device register, but her words are quite apt regarding the latter too).
Now, the ACMA had a spokie say on 27 November 2025 that ‘discussions with industry about a register of devices were “ongoing”’. That was a few weeks after it was leaked that the ACMA had flat-out refused to make such a register public, a position reportedly prompting the telcos to go the BYO route.
This isn’t good enough. The ACMA cannot drag its feet on this, and needs to nut out a solution with industry and technical expert stakeholders fast.
It has already presided over multiple 000 outages and the deaths of innocent people who tried to dial 000 but couldn’t get help in time.
Stepping up to the plate is long overdue for the ACMA.
As it is for the Australian Government at large.
Speaking of which, here’s the next edition of Hardcoded.
