Permanent inbound roaming policy

1. General position

1. This policy outlines Telstra’s position on permanent inbound roaming for Telstra’s international roaming carrier partners accessing Telstra’s mobile network. This Policy may be amended from time to time at Telstra’s discretion without notice.
2. Generally, Telstra doesn’t support international roaming carrier partners unilaterally engaging in permanent inbound roaming on Telstra’s mobile network for the following reasons.
   • There are technical and commercial risks for Telstra in allowing a large number of devices to attach to Telstra’s mobile network in an uncontrolled or unplanned way, as Telstra doesn’t have control over these devices and cannot mitigate against any potential network issues.
   • As Telstra doesn’t have visibility over uncertified devices on its network, it cannot fully support customers of these devices who encounter issues on its network.
   • This can be an attempt to achieve domestic roaming outcomes, which doesn’t align with Telstra’s intended purpose of international roaming arrangements.
3. Where Telstra detects a Permanent Inbound Roaming Service on its mobile network, it may at its discretion, with 60 days’ notice disconnect and ban that service from reconnecting to its network indefinitely.
4. If an international roaming carrier partner has routed 5,000 or more unique Permanent Inbound Roaming Services on to Telstra’s mobile network, Telstra may disconnect those services and ban further services from reconnecting to its network until such time as Telstra and the partner are able to agree appropriate commercial terms for roaming services going forward. Telstra may increase or decrease this qualification threshold with 60 days’ notice.

2. Exception Requests;

1. Whilst the framework above applies to Telstra’s international roaming arrangements, Telstra will consider exceptions (on a case-by-case basis).
2. Exceptions to the position above may be considered by Telstra after analysing information including any business case for Telstra in allowing Permanent Inbound Roaming Services, assessed in accordance with factors including:
   • The type of end customer and application to be supported (e.g., smart meter, connected car, security monitoring, asset tracking, service);
   • Estimated number of services to be permanently deployed over 5 years;
   • Expected average monthly data utilisation per service;
   • Use-case and solution;
   • Originating country;
   • Technology (LTE, LTE-M, NB-IoT, 5G);
   • Business model (B2C, B2B, B2B2C);
   • Deployment start date;
   • Deployment duration;
   • Deployment forecast (e.g., 1,000 devices per month/year);
   • Maximum number of deployed devices;
   • Expected average data utilisation per service;
   • Geographic deployment location, if specific and applicable; and
   • Module (and device, if applicable).
3. If an international roaming carrier partner requests an exception, Telstra will endeavour to provide a response within 60 business days.
4. If Telstra is willing to make an exception and accept a request for Permanent Roaming, Telstra will work with the international roaming carrier partner to agree the terms on which Telstra will provide its Permanent Inbound Roaming Service.
5. Telstra may withhold its consent to any roaming arrangements on its mobile network.

3. Definition of Permanent Inbound Roaming Service

1. Telstra defines a ‘Permanent Inbound Roaming Service’ as a service in a device which:
   1. For non-M2M/IoT devices:
      • has a minimum of 6 Roaming Months in any rolling 12-month period (where a ‘Roaming Month’ is where that service is detected on the Telstra mobile network at least once in a month); and
      • belongs to a single customer account or is on a unique APN with more than 500 mobile devices on the Telstra mobile network.
   2. For M2M/IoT devices:
      • has a minimum of 6 Roaming Months in any rolling 12-month period (where a ‘Roaming Month’ is where that service is detected on the Telstra mobile network at least once in a month); or
      • belongs to a single customer account or is on a unique APN with more than 500 mobile devices on the Telstra mobile network; or
      • belongs to a person or entity which is a resident or resides or operates on a permanent or long-term basis within Telstra’s territory.
2. Unique services will be defined by MSISDN or device IMEI.