Australia’s 3G Shutdown - Why your 4G/5G Phone is now Blocked!

James Parker on 2024-11-02

Australia’s 3G Shutdown — Why your 4G/5G Phone is now Blocked!

Corporate Self Interest and the Failures of Government & Regulators

Table of Contents

YouTube — ‘Australia’s New Firewall IMEI BLOCKED 516,875 Active Phones Overnight + Tourists Phones Blocked’ | Hugh Jeffreys
YouTube — ‘Australia To Block Internationally Purchased 4G/5G Phones As Part of 3G Shutdown’ | Hugh Jeffreys
YouTube — ‘Carriers are Killing 4G & 3G Devices — Your 4G Phone May Soon Stop Working’ | Hugh Jeffreys

Petition

Change.org — Sign the Petition Alarming new changes to Australia's Emergency Calling rules could see thousands of working 4G & 5G phones Blocked by…www.change.org

Introduction

Australia is currently in the midst of the most significant change to the telecommunications landscape it has ever experienced in modern history.

The shutdown of the 3G Mobile Network.

Originally announced by Telstra in late 2019, the shutdown is supposed to usher in a new age of modern high speed communications to power the modern 4G & 5G data dependent world we find ourselves in, and are increasingly reliant on.

SMH — The end is nigh for Telstra’s 3G network; termination set for 2024 - October 2019 https://www.smh.com.au/technology/the-end-is-nigh-for-telstra-s-3g-network-termination-set-for-2024-20191009-p52z0n.html

As they did with the shutdown of 2G in 2018, the telcos & industry have framed this as a necessary step forward in advancing their 4G and 5G coverage.

However, the handling of the shutdown has been met with disruption & delays, mismanagement, industry self interest and an overall lack of preparedness by Government, Regulators and the sector at large.

Whilst shutting down 3G sounds like a perfectly reasonable proposition, the realities with achieving that in the modern landscape of fractured technological standards and cost cutting means this process has been fraught with problems.

All of which have been entirely foreseeable.

Background

The Shutdown of Telstra’s 3G Network was due to originally occur on 30 June 2024, with Optus to follow from September 2024.

Vodafone (TPG Telecom) was the first out of the gate with a planned switch-off from 15 December 2023.

TPG would later realise they got out scot-free, largely free from the controversies to come.

Though everyone has a had part to play in this, including TPG/Vodafone.

On Sunday 17 March 2024 the Communications Minister stated she became aware that approximately 740,000 4G phones (that support VoLTE/4G Calling) would not be able to call 000/Emergency Services after the 3G switch off.

Following on from that March announcement, on 6 May Telstra announced that they would delay their shutdown to 31 August.

Then subject to a Senate Inquiry in July, Telstra and Optus eventually jointly delayed their shutdown until 28 October 2024.

Telstra, Optus to delay 3G network closure amid public safety concerns — 2024–08–14 https://www.abc.net.au/news/2024-08-14/telstra-optus-delay-3g-shutdown/104222598

You can learn more below.

Australia’s 3G Switch-off - Failures of Government & Industry to Prepare A Cautionary Tale of Mismanagement & Consumer Harmsmedium.com

The entire time the industry and telcos have touted the shutdown as a critically necessary step in ensuring we can interact with the modern digital world.

Meanwhile telcos like Telstra continue to post massive profits whilst simultaneously increasing the cost of mobile services for customers, with ever diminishing value in return.

SMH — ‘Telstra profits pass $2b on mobile growth’ — August 2023 https://www.smh.com.au/business/companies/telstra-profits-pass-2b-on-mobile-growth-20230816-p5dx29.html

The Problem

A key factor that the industry has been keen to not draw too much attention to for over a year is the number of 4G & 5G devices that would no longer work, or would only work on some networks, including for Emergency Calling.

The idea that a 4G or 5G phone could somehow be affected by the shutting down of older technologies like 2G & 3G is a completely foreign concept to people, and rightfully so.

The last 20-30 years of 2G & 3G has enabled seamless global connectivity and greatly enhanced competition & innovation in the mobile sector.

Surely 4G & 5G would be an extension of the same, because of course it would!

How could it not be?….. right..?

Well this is where it all starts to fall apart.

Unlike with 2G & 3G, 4G & 5G are Data only standards and have no built-in calling functionality, let alone one as well standardised as the traditional Circuited Switched calling from 2G & 3G (GSM/UMTS).

This becomes a problem as to enable calling over 4G & 5G, devices need to have explicit software/firmware support, especially so for Emergency Calling.

Calling on 4G Networks is enabled through the use of VoLTE (Voice over LTE aka ‘4G Calling’), which is a software/firmware VoIP (Voice over Internet Protocol) calling solution for mobile phones.

The world has used VoIP Calling for decades but introducing VoIP data based calling into the mobile sector has proven very difficult.

Voice Over LTE (4G Calling) devices have been around since as early as 2013, however over years the industry has failed to ensure interoperability.

‘Should we stop the shutdown of 2G/3G to save lives??’ | Rudolf van der Berg - Stratix | EENA 2022 https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view

The global interoperability with devices that people expect and have become accustomed to for the last 20+ years has entirely disappeared and the vast majority have no knowledge that it’s even happened.

You can learn more about the technical specifics regarding calling on 4G in the articles below.

How to Check for Working VoLTE Calling on Android The Problems with VoLTE Interoperability & Standardisationmedium.com

The Little Known Problems with VoLTE Emergency Calling How to Test for 4G Emergency Calling on Androidmedium.com

The 28 October 2024 Shutdown

Starting on Monday the 28th of October Telstra and Optus began their shutdown process.

What many customers were not aware of is later that same day they would be entirely disconnected and blocked from all mobile services on their 4G or 5G Device, even on brand new devices!

Parents that dropped kids off at school or day care early in the morning later found themselves without any mobile service, unable to call or text anyone.

Whether unable to contact employers or family members, many Australians were caught off guard, surprisingly still the numbers to be affected.

Scale of the issue

One would assume that the Shutdown of the 3G network would only impact those with phones from last decade, or those unwilling to upgrade.

However the Government and ACMA was fully aware that people with newer 4G devices would be impacted and in sizeable numbers.

The ACMA and Government had been monitoring the shutdown, and based on numbers from industry expected approximately 258,000 4G mobile phones would be impacted once the shutdown began.

Emergency Call Service Amendment Determination 2024 Explanatory statement | F2024L01353ES Pg9 https://www.legislation.gov.au/F2024L01353/asmade/text/explanatory-statement

However that 258,000 Number is actually an estimate based on an earlier October figure.

On 1 October 2024 the total number of ‘affected phones’ was noted as 516,875 including 3G, 4G & 5G.

More troubling is those numbers include thousands of 4G & 5G Devices that actually work perfectly on 4G, including for Emergency Calling.

Lumped in with ‘incompatible’ devices because the telcos have next to no visibility of what individual devices can make emergency calls over 4G.

Last Minute Messaging to Telstra Customers

For months in advance of the switch-off the messaging from the providers indicated that older and incompatible devices may lose access to calling as the network was shutdown, but at minimum Data & SMS would remain on 4G & 5G devices.

Telstra SMS 3498 System Message

This was true with Telstra up until the 25th of October.

However from Midday Friday the 25th of October, Telstra customers were instead told via SMS their 4G/5G device would be blocked from all services, including Data & SMS.

Text Message Sent to Telstra Customers Midday (AEST) Friday 25 October 2024

Telstra customers were given half a business day’s notice that their 4G or 5G device would be entirely blocked from all services from Monday!

Optus Messaging

From late August Optus had been telling customers that their 4G or 5G device “would stop working” or “would not work”.

However they consistently neglected to use the word “Block”.

Sometimes hiding it within the fine print of emails.

Amaysim is an MVNO Owned by Optus

Someone with a new 4G or 5G device would rightfully assume those messages are wrong and Optus was being overcautious, especially if they recently just upgraded.

People were even told to disregard the message if they’d recently upgraded.

Little did they know their device would be blocked starting from Monday.

You can read more about Optus and their conduct with this below.

Optus — ‘Keeping our customers safe’

Australia’s 3G Shutdown - Telcos to Block Working 4G/5G Phones! Optus — ‘Keeping out Customers Safe’ medium.com

Why this happened

The Amendment to the Emergency Call Service Determination

On the 21st of August the Minister of Communications, Michelle Rowland issued the ACMA with a direction to amend the ‘Emergency Calling Rules’ and require the carriers to ‘cease providing service’ to any phones the carriers have determined cannot call Emergency Services on 4G.

https://www.legislation.gov.au/F2024L01103/asmade/text
ACMA (Emergency Call Service Determination) Direction 2024 — Explanatory Statement https://www.legislation.gov.au/F2024L01103/asmade/text/explanatory-statement

Now on paper this may sound like a reasonable idea, but as with most things the devil is in the detail. Especially anything involving technology.

Such an arguably appropriate and moral decision was made completely devoid of any understanding about how technology actually works, combined with the conflicts of interest in letting the carriers be the sole arbiters of what is allowed and what isn’t.

It was obvious from the outset that this would go wrong.

After learning about the direction from the Minister, in September I tried to warn her about the consequences & harms that would result.

Letter to the Communications Minister - RE 3G Network Shutdown & ECSD Changes — James Parker | 19 September 2024

You can read more about the determination direction from the Minister in the article below.

Australia’s 3G Shutdown - Telcos to Block Working 4G/5G Phones! Silent Policy Change: Telcos to disconnect “Unsupported” Phonesmedium.com

It wouldn’t be until after the shutdown, on the 29th of September would a response letter be sent.

MC24–016817 | Minister Rowland Letter - 3G Shutdown Response — Mr Parker - 29 October 2024

And the response would fail to recognise or acknowledge the harm that was just inflicted to hundreds of thousands of consumers.

The Minister still with the belief that the Industry will be ‘reliably identifying’ affected devices and not simply blocking any devices they didn’t test or sell.

MC24–016817 | Minister Rowland Letter — 3G Shutdown Response — Mr Parker — 29 October 2024

Whilst fundamentality either ignoring or not understanding the serious fairness and competition issues, that will result.

MC24–016817 | Minister Rowland Letter — 3G Shutdown Response — Mr Parker — 29 October 2024

The ‘Public Consultation’

On the 24th of September the ACMA released a draft of the changes to the ‘Emergency Call Service Determination’, along with an Open Consultation Feedback. (The Consultation opened 4 Days after contacting the Minister through the office of a 3G Committee Senator)

ACMA — Proposal to amend the ECS Determination 2024 https://www.acma.gov.au/consultations/2024-09/proposal-amend-ecs-determination

However this consultation was only due to run for 2 weeks until the 8th of October 2024.

Most Consultations by the ACMA run from anywhere from 4–5 weeks depending on the topic and stakeholders involved.

In total there were 40 submissions to the ACMA, including 11 directly from Industry. (Including Industry Groups, MNOs, MVNOs etc)

You would have thought, given the seriousness of totally blocking hundreds of thousands of phones in a matter of weeks, that the ACMA would have ensured a sufficiently long public consultation period.

Or at minimum the Minister would have actually intervened and delayed the shutdown.

Even more questionable is why it was only opened on the 24th of September, when the ACMA had the direction from the Minister weeks earlier in late August/early September.

I, along with other members of the public made submissions to the ACMA with very serious concerns regarding the Minister’s Direction and the Draft put forward by the ACMA.

Submission to the ACMA - RE Proposed changes to the ECS Determination 2024 - James Parker | 2024–10–08

Even the Telcos raised some serious concerns about the technical feasibility of blocking devices.

On Thursday 24 October, the finalised Amendment to the Emergency Call Service Determination was published on the Legilsation.gov.au website.

Emergency Call Service Amendment Determination 2024 https://www.legislation.gov.au/F2024L01353/asmade/text

From that point it became official, the Government (much to some resistance from the Telcos) were going to force the telcos to block over a quarter of a million people and their devices in the span of mere days and weeks.

The concerns of consumers and industry were entirely disregarded.

The somewhat more reasonable suggestion by Telstra to just disable call service and leave Data & SMS was rejected by the ACMA.

If the telco believes a device to be ‘incompatible’ it would be blocked, from all services. No exemptions, no dispute processes, no proof required, simply denied all services!

I own devices that work perfectly but the Telcos don’t recognise they work, this includes devices that have placed multiple calls to 000 over 4G.

Normal 4G Emergency Calling Behaviour (With Active Sim & VoLTE)

Description: In the above example the device successfully places an Emergency Call over 4G with an active ‘VoLTE’ service. This is the intended Calling behaviour for a device that supports 4G Emergency Calls.

The device (Android 9 — Xperia XZ1C — SD 835) was running a GSMA (‘Open Market’) IR.92 + IR.51 VoLTE Modem Configuration.

However, as Vodafone did not sell this model of device and it was not sold in Australia they do not recognise that it supports both VoLTE Calling and Emergency Calling!

Incompatible Devices

Contrast the above with what happens with a device that actually is unable to make emergency calls over 4G.

What people also don’t understand is that these compatibility issues with VoLTE Calling and Emergency Calling are Software Problems, not hardware issues.

Two identical phones running different software can have different VoLTE Calling and Emergency Calling functionality on various networks.

This Industry has tried to pretend that 4G devices that rely on 3G for 000 are ‘hardwired’ this way and the only solution is to buy new devices, when that could not be further from the truth.

Sony Xperia XZ1 — Qualcomm Snapdragon 835 Chipset — Tested Q2 2024 — Extract from Testing

You can learn more below:

The Little Known Problems with VoLTE Emergency Calling How to Test for 4G Emergency Calling on Androidmedium.com

The 8 November Optus Outage

The failure by Optus last year during the 8 November Outage is the key factor behind this change and the new Determination Direction & Rules.

Blocking handsets is to entirely sweep the compatibility problem under the rug.

By making this change, the industry and regulators are entirely absolved of any responsibility or accountability for failing to properly address the issues with Calling and Emergency Calling over 4G.

We need policy that actually requires the industry to actually fix the problem!

Optus reveals 10 times more people affected by triple-0 failures than previously known https://www.abc.net.au/news/2024-01-23/optus-network-outage-triple-0-emergency-calls-wider-than-thought/103380928

ABC News — Optus Outage Inquiry Report — Sep 2024: https://www.abc.net.au/news/2024-09-27/optus-outage-senate-inquiry-report/104406028

In 2019 Optus even said to the ACCC that “VOLTE cannot be the sole technology relied upon to provide voice services. […]” due to “..incompatible handsets.”

An extract is below.

Optus — ‘Optus submission to the MTAS FAD discussion paper’ ACCC — September 2019 — PG5 https://www.accc.gov.au/system/files/Optus%20submission%20to%20the%20MTAS%20FAD%20discussion%20paper.pdf

Optus Outage Review & Findings

In the Government’s subsequent review into the 8 November Optus Outage it was noted that there is minimal if any testing between devices across networks.

An extract from the Report is below.

“Regardless of the technical reasons for the outage, it is clear that more testing of network interoperability is needed to ensure problems are identified and anticipated. The complexity of the carriers’ mobile networks and the necessity of interoperability to deliver Triple Zero calls demands a more thorough approach to testing than is currently in place. 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.

Current testing regimes do not cover all devices sold by all carriers, and there is no system for addressing the capabilities of the devices of customers who bring their own. The countless variations in handsets, handset and SIM settings, and the alternative configurations between nodes within each of the networks, present a significant risk to the certain operation of the camp on functionality in all (or as many as might reasonably be anticipated) circumstances. This needs to be addressed.

The establishment of cross-carrier end-to-end network and device testing including under the wide range of known scenarios would provide information and insight into potential issues before major outages occur. Such testing may have gone someway to anticipating the failure of some calls to connect to Triple Zero on the day of the outage.”

Department of Infrastructure — ‘Review into the Optus outage of 8 November 2023 — Final Report’ — March 2024 — Pg22

The report goes on further to say:

“Australian Standard AS/CA S042.1: Requirements for connection to an air interface of Telecommunications Network. This standard, [..] specifies the requirements for customer equipment (handsets), […]. It includes technical guidance for testing these handsets for various scenarios including accessing the emergency call service. Carriers use this guidance in conducting the testing that they do. There is currently no requirement for universal or cross-industry testing.”

As 2G and 3G calling are well understood and standardised, it hasn’t been necessary to carry out extensive device & network testing.

As the standardisation of 4G VoLTE calling is extremely fragmented, testing for devices is necessary to confirm even basic compatibility, this is due to the industry failing to properly standardise VoLTE calling.

The ACMA, Department and Industry have decided not to properly address the BYOD device issue and will instead now require people to only use ‘supported’ handsets purchased directly from their telcos or associated handset partners.

With this policy change you can now no longer use any device you want from any provider in the world, even if it may work perfectly!

The telcos get to be judge, jury and execution, solely deciding what phones you are allowed to use and where you must have purchased them from.

Optus Blocking Officially Supported Devices

Due to the failures by Optus during the 8 November 2023 outage, in early September began instigating a very regressive device ‘Whitelist’ blocking policy.

Optus — An Important Update on Mobile Handset Safety — 3 September 2024

In essence if they (or their partners) didn’t sell a phone or test it, it’s blocked, even if it’s a supported hardware model!

Optus is even blocking Officially Supported phones that are on their device support list!

I own an 4G Sony Xperia XZ Premium (2018) which is officially supported by Optus & Telstra.

Optus VoLTE Support List ⁣https://www.optus.com.au/support/answer?id=20032
Telstra VoLTE Support List https://www.telstra.com.au/support/mobiles-devices/enable-volte-mobile-phone#compatible-device

I have a Network Unlocked version originally sold through Telstra that is running the Australian Retail Software.

The phone works (worked) perfectly for VoLTE Calling on Telstra and Optus.

VoLTE IMS Registration Status - Voice over LTE Available

However as my device was sold by Telstra, Optus has now blocked it from their network!

Phone not allowed for voice Device Blocking Message —Sony Xperia XZ Premium

It’s exactly the same hardware model, but because it was sold by their competitor and they don’t think it works, it’s entirely blocked!

Even if loaded with the Optus specific software the device would still be blocked as the phone is being denied all service based on the TAC ‘Type Allocation Code’ section of the device IMEI. Not the actual functionality. (The IMEI is essentially the Serial Number, similar to the VIN of a vehicle)

My Telstra Version of the XZ Premium has a TAC of 35923708 Where as an AU Retail versions may have a TAC of 35783808

Both are identical ‘G8141’ Model Devices with the exact same hardware.

IMEI TAC Identifier Example

The conduct by Optus and the Telcos is extraordinarily anti-competitive and doesn’t seem even remotely legal.

Optus Blocking New Phones Purchased Retail

Even some brand new phones recently purchased in retail stores here have been blocked by Optus and the telcos, those customers are currently without any 4G service!

Notice on 3G Shutdown and Network Connection for Xiaomi Devices — 31 October 2024 https://xiaomitech.com.au/blogs/news/notice-on-3g-shutdown-and-network-connection-for-xiaomi-devices

Impacts on Consumers

A key element that has been neglected by Government, Regulators and Industry from the beginning is the impact on consumers.

They may like to proudly display and talk about how there are processes and systems in place to deal with the ‘vulnerable & elderly’, patting themselves on the back whilst simultaneously failing to actually ensure that consumers are correctly informed and protected during this process.

On the 14th of May Amaysim sent out a marketing email saying “IT’LL BE MAYHEM” when the switch-off occurs.

This sort of marketing material was extremely unnecessary and only served to drive people to panic buy new phones.

Media Coverage

Over the past year the bulk of the reporting that has been in the media (primarily that of the commercial TV networks) has been (and continues to be) very poor, for months there has been essentially little to no mention as to the possible impacts to 4G and 5G devices.

On 21 August 2023 both 7 News and 9 News aired stories about the 3G switch-off with their 6PM Bulletins.

Both TV Networks included interviews from the providers however the fact that 4G and 5G devices could be affected wasn’t mentioned once!

YouTube - Australians warned of upcoming 3G switch-off from Telstra, Optus & Vodafone - 7 News | 2023-08-21 https://web.archive.org/web/20240124101628/https://www.youtube.com/watch?v=yJZotwC3hjg
YouTube - 3G network to shutdown in a number of months - 9 News Australia | 2023-08-21 https://www.youtube.com/watch?v=JiRdec-E8ps

On 22 August 2023 I once again contacted the office of my Local Member Anika Wells regarding the TV news coverage. I asked for any updates from the Minister’s Office regarding the concerns I raised on 6 June 2023.

I said “Last night (21/08) the Brisbane 6PM nightly news bulletins on Channel 7 and Channel 9 covered the switch-off, but both failed to mention the VoLTE support issue and the impact the switch off will have on 4G Devices that lack VoLTE support on Australian networks. It seems like the telco’s aren’t being entirely upfront about this issue to the media and its critical people are properly informed about this.”

On 24 August 2023 I received a response that said:

“We are yet to receive an update, we are liaising with Minister Rowland’s office on the status of the update”

It would take another month to receive a response on 25 September 2023.

I also raised these concerns with the aforementioned TV networks via email on 22 August. One of the networks did respond to my email, and I had an hour long on-camera interview with them in early September 2023, however the network never aired the story.

No explanation was provided. After a number of follow-ups on 15 November they finally advised “At this stage we aren’t running the story sorry.”

Blindly listening to industry and their Government relation lobbyists has resulted in the outcome we find ourselves in today.

By stark contrast France will have 3G until approx 2028/2029 and the UK will be keeping their 2G network around until approx 2030/2033.

Both countries have more than 2.5x our population.

Kore Wireless — ‘Global 2G & 3G Network Closures’ https://www.korewireless.com/2g-3g-network-sunset-dates

Mobile UK — ‘2G/3G Switch Off’ https://www.mobileuk.org/2g-3g-switch-off

Costs to Consumers

Within the ACMA ‘ECS Explanatory Statement’ they set out a number of regulatory options in regards to the shutdown, including the blocking of working devices in Option 2.

Within the paper they set out the expected costs to consumers.

ACMA Assumes all ‘affected phones’ are Low End Phones, equivalent to $250 Samsung!

It assumes that the average replacement cost for a consumer is only $250, and multiply over the total number of affected devices in use that consumers should be expected to bear in excess of $83 Million in costs.

ACMA Explanatory Statement registered 24/10/2024 to F2024L01353 | Page 37 https://www.legislation.gov.au/F2024L01353/asmade/downloads

The overall proportion of costs for this approach will see 55% of the financial burden borne by consumers!

ACMA Explanatory Statement registered 24/10/2024 to F2024L01353 | Page 27 https://www.legislation.gov.au/F2024L01353/asmade/downloads

In my submissions to both the Optus Network Outage and the 3G Network Shutdown Senate Inquiries I warned that:

Requiring Optus, Telstra or Vodafone VoLTE firmware on mobile devices provided by those companies will reduce choice for consumers in addition to allowing the major telcos to exert more control over the smartphone and telecommunications space.

Australian consumers should be free to purchase devices from any retailer, online store or international brand and have it work here in Australia, just as they have been able to do for decades with 2G & 3G. The consistent standardisation of 2G & 3G has enabled seamless global connectivity and greatly enhanced competition in the mobile sector.

Currently providers are able to use this Telco Specific VoLTE firmware requirement as a stealth way of network locking their devices and preventing customers from switching to competitors or from using ‘BYO’ devices.

All of that has now occurred!

Impacts on Tourists & Roamers

What people may not also been aware of is that the devices used by many International Tourists and Roamers were also entirely kicked off the networks of Telstra & Optus on Monday Morning (28 Oct).

Even though the Direction from the Minister and Legislation by the ACMA states that Travellers should be exempt for up to 90 days.

ACMA (Emergency Call Service Determination) Direction 2024 — Explanatory Statement | Page 2 https://www.legislation.gov.au/F2024L01103/asmade/text/explanatory-statement

The telcos in their Submission to the ACMA’s Open Consultation did warn they would struggle to exempt Roamers from the device blocking rules.

Telstra — ECS Determination Public Submission — 9 October 2024 — Page 10 https://www.acma.gov.au/consultations/2024-09/proposal-amend-ecs-determination

However the ACMA and the Minister both seem to think that the rule of law can somehow overcome technological complexities and limitations.

A story we’ve heard before from many different Governments.

Telstra | 3G network closure — Frequently asked questions - November 2024 https://www.telstra.com.au/support/mobiles-devices/3g-closure

The failure to fully contextualise and understand the implications of this issue highlights the very clear lack of oversight there has been with this entire shutdown process.

For some context, in April 2019 the ACMA said there was ‘no clear indication of migration paths towards the use of VoLTE handsets’.

Yet Telstra announced a 3G switch-off date later that same year for mid 2024.

ACMA — ‘Reconfiguring the 900 MHz band — Options paper’ — April 2019

“One of the key issues for licensees is the uncertain timeline for the proliferation of Voice Over LTE (VoLTE)-enabled devices among consumers. The ACMA sought information from incumbent licensees on the expected timing and speed of consumer migration towards the use of VOLTE handsets, but still has no clear indication of intended migration paths. In the absence of receiving any further information to support a more detailed assessment, the ACMA considers that the proposed timeline outlined in this option (i.e. a mid-2024 clearance date for existing apparatus licences) provides enough opportunity for carriers to mitigate risks to the continuity of consumer services.”

Based on the above information it appears that little (if any) consideration was ever given to ensure handsets were compatible before allowing the providers to restructure any of the 3G Bands, let alone a complete switch-off of 3G.

When the ACMA made that assessment Android and iOS didn’t even have VoLTE Roaming Support. (Android 12–2021, iOS 15–2021)

It’s clear the switch-off dates have been chosen not on specific compatibility or standardisation criteria, but rather based on commercial interests.

You can learn more below.

Australia’s 3G Switch-off - Failures of Government & Industry to Prepare A Cautionary Tale of Mismanagement & Consumer Harmsmedium.com

Now Tourists with blocked 4G & 5G phones find themselves only able to connect to the Vodafone network. (Though some devices used by Roamers were blocked on Vodafone as well.)

Roaming Customers unable to Connect to Optus or Vodafone from Monday 28 October 2024

Issues with VoLTE & Roaming

Worse still many lost the ability to make or receive calls via their Roaming Sim Card as VoLTE Roaming was only available on Optus and Telstra’s Networks.

Seems there were some complaints after that happened, so now VoLTE Roaming is working on Vodafone AU.

Furthermore to have a device with VoLTE Roaming Calling support, Optus advises you need a Samsung/Android Phone with Android 12 or above.

‘Optus Device Compatibility & VoLTE Roaming Activation’ — May 2024 https://www.optus.com.au/mobile/plans/international-roaming/volte
Android 13 distribution April 2023 — Source: Android Authority & 9to5Google https://www.androidauthority.com/android-13-distribution-2023-3312803 https://9to5google.com/2023/04/13/android-13-market-share-stats/2803

However Android 12 was only released in late 2021 so people who have Android phones older than 2020/2021 are likely to encounter issues with either switching providers, when travelling overseas or when making calls over 4G.

Devices from Android version 4 to 11 (2020) make up 69% of the Global Android Device Market as of April 2023.

4G/5G Devices without VoLTE calling support currently rely on the 2G/3G Networks to make and receive calls, this is via a technology called Circuit Switched Fallback (CSFB).

Even without the blocking, once 3G the shutdown is complete many 4G & 5G phones used by Tourists will no longer be able to make calls or emergency calls in Australia either via Roaming or with a local sim card installed.

Telstra & the Telcos were asked at the 3G Senate Inquiry on 24 July:

“How many roaming devices are reliant on the 3G network to make or receive roaming calls or Emergency Calls?”

They didn’t know that Answer and had to take it on Notice.

In the answers to Telstra’s Questions on Notice from the 3G Inquiry they said that in July there were 2.3 million international roaming devices connected to their network and that Telstra ‘cannot confirm the 4G Voice calling capability of the devices’!

Telstra — Answers to questions taken on notice at a public hearing on 24 July 2024 (received 1 Aug 2024) https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown/Additional_Documents

Industry Awareness of the Problem

At the April 2022 European Emergency Number Association (EENA) Conference, Dutch Telecoms Consultant Rudolf van der Berg made a presentation to the conference outlining serious issues with the current 4G calling standards and protocols.

One of the major issues he raised is that many 4G Phones (both European & International) are completely unable to call (911/112) Emergency services without the presence of 2G/3G (Circuit Switched Calling) Networks.

These issues were noticed following on from the 3G network shutdowns that occurred in the US around that time and he warned this will become a widespread issue as 2G/3G networks are gradually shut down across the globe.

The link to his presentation on the EENA YouTube page can be found below.

Mr van der Berg is from the Dutch Telecommunications Consultancy firm Stratix, he was also an Economist/Policy Analyst at the OECD and has worked for many years in the Telecom Industry.

YouTube -‘EENA 2022: Access to emergency services is being impacted by the lack of VoLTE interoperability

These issues aren’t well known to the general public however in his EENA presentation he says these issues are “Common Knowledge” in the industry and that “..there is nobody who feels responsible to fix this”. (16:45)

On a slide in his presentation it says ‘telecom sector will deny [there’s a problem], be angry over 5G investment and bargain for half baked measures..’

‘Should we stop the shutdown of 2G/3G to save lives??’ - Slide 14 | Rudolf van der Berg — Stratix | EENA 2022 https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view

Response from Industry Groups

In response to his EENA 2022 presentation, the GSMA (one of the world's largest industry groups for the Telecom Sector) established a task force to try and address these issues.

The GSMA directly referenced the EENA video in a presentation about this problem to industry last year in 2023, a link to the slide deck from that presentation is below.

GSMA — ‘Additional Test Cases for IMS Emergency Calling’ — ITU-T Webinar — Wayne Cutler — 2023–06–21 https://www.itu.int/cities/wp-content/uploads/2023/06/3_Wayne-Cuttler.pdf

The aim of the taskforce is to improve the standards and advocate for device manufacturers, carriers and GSMA member organisations to align their devices and networks with a unified standard.

It’s worth mentioning that Telstra, Optus and TPG/Vodafone are all members of the GSMA, so they cannot pretend they had no awareness of the of these issues prior to last year and the minimal progress made to fix the problem.

GSMA — ‘How we’re addressing VoLTE emergency call issues’ — 2023–05–12: https://www.gsma.com/services/blog/how-were-addressing-volte-emergency-call-issues/

This work is still ongoing and it’s still very much NOT solved globally. Major compatibility issues remain with many networks, device chipsets, handset models and different calling systems.

Lack of Government Oversight with Vodafone

Late January/Early February Vodafone customers started writing to the Minister complaining they lost call service on new VoLTE enabled 4G/5G Phones.

FOI 24–354 — Document 25

Initially these people were told their device ‘may be malfunctioning in some way’ and to contact the manufacturer or retailer.

FOI 24–354 — Document 26

FOI 24–354 | Pages 54 of 147 [PDF Page 42] & 66 of 147 [PDF Page 54]

Furthermore, in emails released under FOI (in advance of the 3G inquiry), it was revealed that I was the only person in the entire country prior to February this year to warn the Minister and Government about the unintended consequences of switching off 3G and 4G devices being unable to make calls and Emergency Calls.

(My original 6 June email to the Minster released under FOI, starts page 4) FOI 24–354 | Correspondence to, and responses from, the Minister for Communications relating to the shutdown of 3G networks between 27 March 2023 and 27 March 2024.

On the 9th of February 2024 the Department of Infrastructure was talking to Optus regarding my 16 November ‘Optus Inquiry Submission’ which is the same day the Optus hearing was set to sit again. (The hearing was cancelled on 8 Feb due to a reported Illness with the Chair)

FOI 24–352 Quarterly reports from Telstra and Optus regarding 3G network switch offs from 27 March 2023 to 27 March 2024

Seems the Department wasn’t happy with the answers from Optus and the new complaints from Vodafone customers.

Then on 26 February the providers briefed the Government about the issue of 4G VoLTE enabled phones being unable to call 000.

FOI 24–353 — Document 6 [FOI 24–353 — Senator Rennick 20240724] — Page 55 of 75 [PDF Page 50] https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown/Additional_Documents

A few weeks later in March, the Minister held a press conference and announced 740,000 4G VoLTE capable phones wouldn’t be able to call 000 post shutdown. (Again that didn’t include all of the 4G/5G phones that wouldn’t be able to make any calls)

YouTube — ‘3G Switch-Off Could Stop Triple-Zero Calls — 10 News First’ — 17 March 2024 (Quote at 1:45) https://www.youtube.com/watch?v=iK98wI6d-W0

After that press conference the messaging from the Department would change and included ‘categories’ of affected devices.

MC24–001972

TPG/Vodafone’s awareness of the 4G Emergency Calling Issue

Sometime between late July and August 2023 Vodafone removed a number devices from the ‘Supported VoLTE Devices’ page on the Vodafone Website. Many of these devices are able to make calls on 4G (with VoLTE) on Vodafone but not to Emergency numbers.

I first noticed a number of devices were missing from the website on 31 August 2023 when registering the sim card I purchased for device testing. (The removed devices were still listed on 10 July 2023).

I had suspicions a number of those devices likely had compatibility issues given when they were released.

Little did I realise at the time that I just witnessed what appeared to be Vodafone hiding the problem from the public.

Vodafone was not required to provide any formal quarterly reporting to the Department and Government, so it does bring into question their awareness of the scale of the compatibility issues last year, and the reasons why these devices were removed at the time without any alarms being raised for customers.

Additionally a number of the devices they removed from their list are still in some cases on Telstra’s and Optus’s Support List, which means many of these potentially affected devices may still be in use and circulation.

In some instances the Telstra and Optus Firmware versions of those devices support Emergency Calling over 4G but not necessarily VoLTE Calling on all networks.

A summary of the removed devices are below. Archived copies of the Vodafone website can be found on The Internet Archive ‘Wayback Machine’.

Devices Removed from Vodafone’s Website between July-August 2023

Further note, some of the above devices will have working calling and emergency calling when used with either Telstra or Optus Network Sim Cards but when a Vodafone Sim Card is inserted the phone may continue to make calls but will lose the ability to make 4G Emergency Calls.

Internet Archive — Wayback Machine — ‘Vodafone AU VoLTE Device Support List’ — Before Removal — 2023–06–06

Internet Archive — Wayback Machine — ‘Vodafone AU VoLTE Device Support List’ — After Removal — 2023–10–25

Learn more below

Vodafone’s awareness of the 4G Emergency Calling Issue

Australia’s 3G Switch-off - Failures of Government & Industry to Prepare Vodafone’s awareness of the 4G Emergency Calling Issue medium.com

Device Survey & Results

Post shutdown I launched a Google Forms Survey in order to gather information in regards to the devices impacted, the messaging received by customers and the overall impacts the shutdown & blocking of devices was having on customers.

Australia’s 3G Shutdown — 4G/5G Device Blocking & Capabilities Submission Form https://docs.google.com/forms/d/1TnX_McW4uMMrb8iu1GQCzthhq1gIs0x34cddMzhluKY/viewform

The numbers paint a very stark picture and reveals how badly managed the communication for this process has been. Including that by the traditional major TV & News Media Networks.

Within the survey results it’s very clear that the the vast majority cannot afford to buy a new phone.

Of the over 300 Surveyed, 83% of people said purchasing another suitable device would have either a Moderate or Major Financial impact!

Australia’s 3G Shutdown — 4G/5G Device Blocking & Capabilities Submission Form (Public Version) https://docs.google.com/spreadsheets/d/1FaJYdW0l9ZydAn8gS_fo-ix73XCPJBldOoJP0Lvwqpo

Over 75% of respondents also say they’ve not been offered a replacement device by their provider! (Let alone one fit-for-purpose or like-for-like!)

Consumers currently have minimal if any recourse to dispute their device being blocked and are being forced to buy new phones.

List of Blocked Devices

Below is a sample of the devices that have been blocked by various the telcos. (Note: Some devices are only blocked on some networks at this point in time.)

Sample Extract of Blocked Devices https://docs.google.com/spreadsheets/d/1FaJYdW0l9ZydAn8gS_fo-ix73XCPJBldOoJP0Lvwqpo/

What you can do!

If you are an Australian Citizen please contact to your local Federal Member of Parliament, Senators, the Communications Minister, the ACCC, the TIO and your Telco.

Either via email, phone or old fashion snail mail. The more messages sent the better.

Provide them information as to what has occurred in your situation, what sort of device you have, if VoLTE was confirmed working before being blocked etc. Also detail how you have been mislead during this process.

You can find out your electorate at the link below.

When contacting your politicians please remember to include your electorate or suburb, as well as a name and basic contact details. If you don’t provide where you are from you won’t get a response.

AEC Electorate: https://electorate.aec.gov.au/

ACCC — Report a Consumer Issue: https://www.accc.gov.au/about-us/contact-us-or-report-an-issue/report-a-consumer-issue

Communications Minister Contact https://minister.infrastructure.gov.au/rowland/contact

Sign this Change.org Petition Short Link: https://www.change.org/StopTelcoDeviceBlocking Full Link: https://www.change.org/p/stop-telco-4g-5g-device-blocking-volte-restrictions-australia-s-3g-shutdown

Change.org — Sign the Petition Alarming new changes to Australia's Emergency Calling rules could see thousands of working 4G & 5G phones Blocked by…www.change.org

Relevant Articles

Australia’s 3G Shutdown - Telcos to Block Working 4G/5G Phones! Silent Policy Change: Telcos to disconnect “Unsupported” Phonesmedium.com

Australia’s 3G Switch-off - Failures of Government & Industry to Prepare A Cautionary Tale of Mismanagement & Consumer Harmsmedium.com

How to Check for Working VoLTE Calling on Android The Problems with VoLTE Interoperability & Standardisationmedium.com

The Little Known Problems with VoLTE Emergency Calling How to Test for 4G Emergency Calling on Androidmedium.com

Other Videos

YouTube — Senate Inquiry — Shutdown of the 3G mobile network | 23/07/2024–2hrs 10m — James Parker
YouTube — Senate Inquiry — Shutdown of the 3G mobile network | 24/07/2024 — Canberra ACT