People died because their phones couldn’t connect to Triple Zero during three separate incidents between November 2023 and November 2025.
The November 2023 Optus outage left millions unable to call emergency services. Then it happened again in September 2025. And in November 2025, a TPG customer died during a medical emergency when their Samsung phone couldn’t complete the call.
This guide examines the regulatory response to Australia’s telecommunications emergency call crisis, analysing the new enforcement powers and compliance framework.
So what’s Australia doing about it? Creating a regulator with teeth. The Triple Zero Custodian legislation passed in October 2025 gives government power to force compliance across carriers and device manufacturers. ACMA can now mandate device blocking, impose penalties up to $30 million, and require real-time outage reporting.
This is a shift from reactive incident response to proactive safety enforcement. If you’re managing telecommunications infrastructure or vendor relationships, these compliance requirements will affect your device selection and any services that depend on carrier networks.
What is the Triple Zero Custodian role in Australia?
The legislation creates an independent body housed within the Department of Infrastructure. Unlike ACMA, the Custodian doesn’t enforce rules directly. Instead, it sets strategic direction and can request ACMA to investigate carriers, require information, or direct action.
Think of it as a strategic layer above ACMA’s operational enforcement. The Custodian helps you prepare for outage events and oversees the entire ecosystem. When problems emerge, the Custodian refers matters to ACMA for investigation and enforcement.
The legislation implements a recommendation from the Review into the Optus Outage of November 2023. That review found no single body could see the whole picture, which hampered accurate and timely advice during the crisis.
Starting November 1, 2025, carriers must maintain a public register of network outages with real-time reporting capability and test Triple Zero during upgrades and maintenance.
What powers does ACMA have to enforce emergency call regulations?
ACMA implements the Emergency Call Service Determination, which defines technical requirements, testing standards, and carrier obligations. The new legislation provides ACMA with powers to direct action from carriers to ensure effective emergency calling.
The enforcement mechanisms are straightforward. Financial penalties for non-compliance, with the maximum recently increased from $10 million to $30 million. Optus paid $12 million for the 2023 outage. Under the new framework, that penalty could reach $30 million.
There’s also device blocking directives when phones can’t reliably complete emergency calls, and compliance investigations following failures.
The new rules starting November 1, 2025 require carriers to subject handsets to special tests designed to evaluate network switching during emergency calls. This means testing how devices perform when base stations experience outages and power down signals.
Real-time reporting requirements force immediate transparency. When network disruptions affect emergency calling, carriers must report to ACMA and emergency services immediately. Not hours later. Not the next day. Immediately.
ACMA selected the National Telecommunications Resilience Centre at University of Technology Sydney as the new testing provider, established in response to the Optus outage review.
How does the device blocking mechanism work for non-compliant phones?
When devices fail emergency calling tests or demonstrate real-world failures, carriers must block them from networks. The Emergency Service Call Determination requires all mobile operators to block devices that aren’t configured to access emergency call services.
The process balances public safety with consumer impact. Carriers must provide 28-day notification before blocking, giving customers time to update firmware or replace devices.
Here’s the timeline: testing failure → customer notification → 28-day waiting period → network blocking. During that period, carriers must explain the non-compliance issue, offer remediation options like firmware updates, and help with device replacement if updates aren’t available.
And blocking isn’t limited to emergency calling. Devices lose access to all Australian mobile networks for voice, data, and messaging.
The Samsung firmware issue on Vodafone‘s network in November 2025 prompted the first large-scale blocking under the new rules. An estimated 50,000 older Samsung devices face blocking unless patched or replaced. The tally of affected models stands at 71 and growing, with 11 belonging to older product series using software that can’t be patched.
TPG CEO Inaki Berroeta put it bluntly: “Customer safety remains our highest priority. This is a tragic incident… We urge all customers with outdated software to replace or update their devices without delay.”
If you’re concerned about whether your device is affected, see our guide on checking your Samsung phone’s Triple Zero capability.
What is camp-on technology and why does it matter for emergency calls?
Camp-on is the fallback mechanism that lets your phone connect to any available network for emergency calls, not just your home carrier. When operating correctly and according to industry standards, mobile handsets automatically seek alternative mobile service when their home networks are unavailable.
Here’s how it works. Your primary network goes down. Your phone detects it can’t reach your carrier. Instead of showing “no service,” the phone scans for other networks and camps-on to make the emergency call. A Telstra customer’s phone might use Optus or Vodafone networks. No commercial roaming agreements required. It happens automatically.
VoLTE (Voice over LTE) adds complexity. Emergency calls route over data networks rather than legacy circuit-switched systems. This requires the device firmware to detect emergency calling state, establish a priority data bearer, and route the call correctly. When firmware gets this wrong, camp-on fails.
The Samsung firmware issue demonstrated complete failure. Firmware locked affected handsets to Vodafone’s shuttered 3G network, leaving them unable to switch and place emergency calls when Optus and Telstra’s mobile networks were down or out of range.
Sources familiar with the technical details called the configuration “highly irregular” and even “unheard of” in mobile engineering circles.
ACMA’s new testing rules target camp-on performance. Carriers must test how handsets perform when they have to switch networks to place emergency calls, including scenarios where base stations experience outages and power down signals.
How do Australia’s Triple Zero regulations compare to the FCC in the USA?
Australia’s model concentrates power in a centralised regulatory authority. The Triple Zero Custodian provides strategic direction while ACMA handles operational enforcement. Device blocking is mandatory. Testing protocols are specified. Penalties are explicit.
The USA’s FCC takes a different approach. Self-regulation frameworks dominate, where carriers certify compliance voluntarily. The FCC can fine carriers for 911 failures but historically relies on industry compliance and post-incident enforcement. There’s no federal equivalent for mandatory device blocking.
Both countries experienced emergency calling failures that drove reform. But the responses differ in centralisation and enforcement philosophy. Australia mandates testing protocols through the Emergency Call Service Determination. The USA relies more on carrier-defined standards.
For businesses operating in both jurisdictions, this creates different compliance landscapes. Australian operations face clearer obligations but less flexibility. US operations have more flexibility but less regulatory certainty about what constitutes adequate compliance.
What are the compliance obligations for telecommunications carriers under the new framework?
Starting November 1, 2025, carriers face a comprehensive set of requirements. Mandatory compliance testing on all devices before network deployment and after firmware updates. Testing must validate camp-on fallback behaviour under network outage conditions.
Real-time reporting of network outages affecting emergency calling goes to both ACMA and emergency services. Immediate notification, not hours or days later.
Device blocking implementation within regulatory timelines when ACMA issues directives.
Carriers must maintain emergency call routing infrastructure that meets camp-on technical requirements defined in the Emergency Call Service Determination. This includes coordination with device manufacturers to distribute firmware updates addressing emergency calling bugs.
When ACMA launches compliance investigations, carriers must respond and provide testing evidence. Financial penalties apply for failures to meet emergency calling reliability standards.
All three major carriers now regularly conduct handset tests and warn consumers about dangers of continuing to use handsets with problems placing Triple Zero calls. These compliance requirements have prompted significant operational responses from carriers, with some restructuring their network operations to meet the new standards.
What caused the fatal Triple Zero failures that triggered regulatory reform?
The November 2023 Optus outage came first. Network failure prevented millions from calling emergency services. Optus paid $12 million for that failure.
Then September 18, 2025. Another Optus outage involving emergency call services resulted in over 600 emergency calls failing. At least three deaths linked to this outage. Optus was first alerted at 2:51pm, initially affecting around 10 calls. By 8:05pm, 100 emergency calls had been missed.
The response delays made it worse. Optus CEO Stephen Rue contacted ACMA at 2:30pm on September 19 – nearly 24 hours after initial awareness. Federal government notification came at 4pm.
The technical cause? A firewall upgrade at Optus Regency Park exchange in South Australia went wrong. But the deeper issue was systematic: network monitoring systems previously outsourced to Nokia teams in India and Australia failed to catch and escalate the problem.
The Samsung firmware bug that locked devices to Vodafone’s retired 3G network meant camp-on failed completely, preventing emergency calls even when alternate networks were available.
The pattern is clear: carriers prioritised commercial network operations over emergency calling reliability testing. Voluntary compliance failed to protect public safety. Deaths occurred before regulatory mechanisms could enforce accountability.
The new regulatory framework represents Australia’s response to these telecommunications safety failures, shifting from voluntary compliance to mandatory enforcement with substantial penalties and oversight.
FAQ Section
Can I sue my telecommunications carrier if I cannot reach Triple Zero during an emergency?
The consumer liability framework operates separately from regulatory enforcement. ACMA penalties fund government oversight, not victim compensation. You can pursue civil litigation for negligence or breach of service obligations if emergency call failures cause harm. Legal precedent is developing following the recent fatalities. Consult legal advice for your specific circumstances.
How do I check if my device is on the blocked list for emergency calling non-compliance?
Carriers must notify you 28 days before blocking. You’ll receive notification via email or SMS with specific instructions. Check your carrier’s website for published lists of affected models. ACMA doesn’t maintain a centralised public registry. If you’re concerned, contact your carrier’s customer service or check for available firmware updates addressing emergency calling issues.
What testing procedures can detect emergency calling failures before deployment?
Compliance testing simulates network outage conditions to validate camp-on fallback behaviour. Tests must evaluate how handsets perform when they have to switch networks to place emergency calls. This includes scenarios where base stations experience outages and power down signals. The Emergency Call Service Determination specifies mandatory testing protocols. Carriers must test devices before deployment and after firmware updates.
How does the 28-day notification period balance safety with consumer impact?
The period provides time to update firmware or obtain replacement devices before network blocking. Carriers must explain non-compliance, offer remediation options, and assist with transitions. Too short creates consumer hardship. Too long delays safety improvements. The 28-day window provides a reasonable transition period.
Who is responsible when firmware bugs prevent emergency calls – carriers or manufacturers?
It’s a shared responsibility model. Manufacturers develop firmware meeting emergency calling standards. Carriers test devices before network deployment. When firmware bugs prevent emergency calls, both parties have failed: manufacturers distributed non-compliant firmware and carriers deployed it without adequate testing. The new framework holds carriers accountable for testing compliance regardless of manufacturer responsibility, which incentivises thorough validation.
What happens to my phone service if my device is blocked for Triple Zero non-compliance?
Complete network service loss. Not just emergency calling. Your device can’t connect to any carrier network for voice, data, or messaging. Blocking protects public safety by ensuring networks only carry devices with reliable emergency calling. You must update firmware to fix compliance issues or replace the device with a compliant model to restore service.
How do European Union emergency call regulations differ from Australia’s Triple Zero framework?
The EU coordinates 112 emergency services through BEREC (Body of European Regulators for Electronic Communications) but lacks a single centralised custodian authority. Member states implement regulations nationally with EU-wide standards. Australia’s Triple Zero Custodian provides stronger centralised enforcement compared to the EU’s coordination model. Both mandate emergency calling fallback mechanisms similar to camp-on.
What are the technical requirements for VoLTE emergency calling reliability?
VoLTE emergency calls require IMS (IP Multimedia Subsystem) emergency bearer establishment over data networks. The device must detect emergency calling state, establish a priority data bearer, and route calls to emergency services. Firmware must support camp-on fallback when home network VoLTE service is unavailable. The Emergency Call Service Determination specifies technical standards carriers and devices must meet.
Can the Triple Zero Custodian force carriers to upgrade network infrastructure?
The Custodian’s authority focuses on emergency calling compliance rather than general infrastructure investment mandates. It can’t directly mandate specific technology deployments but can enforce reliability outcomes that may require infrastructure upgrades.
What penalties can ACMA impose for Triple Zero failures?
Optus paid $12 million for the 2023 outage. The maximum penalty was recently increased from $10 million to $30 million for carriers failing to follow Triple Zero rules. ACMA can directly enforce contraventions through court proceedings or infringement notices.
How do these compliance requirements affect technology procurement and vendor management?
The framework requires pre-deployment device testing and post-update validation. Carriers face penalties for deploying non-compliant devices. Monitor ACMA guidance on Emergency Call Service Determination requirements for specific technical obligations. Plan device replacement programmes for non-compliant models. Document compliance testing procedures for regulatory audits. Consider international regulatory differences for multinational operations.
Will old phones stop working on Australian networks due to new compliance rules?
Device blocking targets specific non-compliant models failing emergency calling tests, not all older devices. Phones meeting camp-on and emergency calling standards remain compliant regardless of age. An estimated 50,000 older Samsung devices face blocking due to the firmware issue. Carriers must notify customers before blocking, providing firmware update or replacement opportunities.
