Transparency in Telco Advertising

New Zealand's Commerce Commission and Australia's ACMA increase scrutiny on bundled pricing and offer disclosures.

Heath Gibson · Executive Manager – Industry Intelligence and Insights at NBN Australia22 September 2023Period: September 20234 min read

Last updated 8 June 2026

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New disclosure requirements proposed by NZ Commerce Commission for bundled offers

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Direction issued to Starlink by ACMA for TCP Code breach

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Companies covered:StarlinkCommerce CommissionACMATIOVenture Insights

Abstract

This report analyses the increasing regulatory pressure on telecommunications providers in Australia and New Zealand regarding advertising transparency. It highlights the New Zealand Commerce Commission's proposed disclosure requirements for bundled offers and the ACMA's recent sanction against Starlink for failing to disclose promotional end dates. The brief argues that low consumer trust is driving regulators away from co-regulation toward direct intervention, with significant implications for how retailers market multi-product bundles and manage contract terms.

Key Takeaways

New Zealand’s Commerce Commission has proposed 6 new disclosure requirements for any bundle containing at least one telco service.
Retailers must now prominently disclose if a bundled plan price is higher than a comparable standalone plan.
The ACMA sanctioned Starlink for failing to specify an end date for a website promotion run during June and July.

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Frequently Asked Questions

The Commerce Commission is implementing 6 new disclosure requirements for any bundle containing at least one telecommunications service. Retailers are now obligated to prominently disclose if a bundled plan's price exceeds that of a comparable standalone offer, addressing consumer transparency issues identified as early as 2022.

Regulators are moving toward direct intervention, evidenced by the ACMA issuing 1 formal direction to Starlink for failing to disclose promotional end dates. This shift signals that the previous co-regulatory TCP Code is now considered insufficient for maintaining industry standards.

All service providers must transition to GST-inclusive pricing and provide granular disclosure of early termination fees for every element within a bundle. These mandates are part of a broader push by the TIO to establish a new registration scheme that enforces minimum standards for financial viability.

Transparency in Telco Advertising

Abstract

Key Takeaways

Frequently Asked Questions

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