Post #106 - Full Marks -

Telco complaints fell 6.5 per cent last year. Telstra’s fell 15.3, Optus’s 10.3, iiNet’s 23.6 – the last from a fixed-line business that shed 116,000 subscribers, which is one way to improve a scoreboard. Vodafone’s rose 13.9, every quarter of the year worse than every quarter of the year before, while thirty thousand prepaid services quietly left underneath it. In the final quarter the industry shed more than 1,700 complaints. Telstra 583. Optus 578. Vodafone thirty-six. The chief executive collected $3,053,206 on a customer score the company marks itself, which printed at maximum. From this year the ombudsman’s number counts too. Going forward only.

The Telecommunications Industry Ombudsman published its annual report for 2025-26, and the industry is entitled to a decent headline. Complaints fell 6.5 per cent to 53,834. Internet complaints down 7.1 per cent. Landline down 21.2 per cent. Delays, inaction and poor service, still the largest single category in the country at 33,165 complaints, or 61.6 per cent of everything, down 4.7 per cent. Even the unresolved matters that bounce back to the Ombudsman after a referral fell 8.1 per cent.

Australian telcos had a better year at the thing they are worst at. Congratulations are in order and this masthead extends them without reservation.

Then one opens the provider table, and the congratulations become rather more selective.

The year everybody improved

Telstra recorded 18,541 complaints, down 15.3 per cent. Optus 12,181, down 10.3 per cent. The two largest carriers in the country, between them carrying the overwhelming majority of Australian services, each took a double-digit bite out of their complaint load in twelve months.

TPG, the brand, recorded 2,430, down 8.6 per cent. iiNet 1,488, down 23.6 per cent, the steepest fall of any major brand in the country.

Vodafone recorded 5,899. Up 13.9 per cent.

Every comparison available runs the same way. The industry fell and Vodafone rose. Telstra fell and Vodafone rose. Optus fell and Vodafone rose. And, this is the part worth sitting with, Vodafone’s own siblings fell, and Vodafone rose. Same parent. Same board. Same complaint-handling policy, approved by the same committee and administered by the same General Counsel this masthead has had cause to write about before. Same outsourced contact centres, measured on the same average handling time.

And the direction is the whole point. When the national total is falling, an increase is not merely bad in isolation. It is disproportionate by definition: every complaint Vodafone added last year, it added into a market that was producing fewer of them.

Improvement by subtraction

Although before anybody orders a cake, it is worth asking what iiNet actually did.

On the published record, nothing.

TPG does not report iiNet’s customer numbers. It reports Fixed, a single line covering TPG, iiNet and Internode together, and that line lost roughly 116,000 NBN subscribers in FY25, a decline of 6.9 per cent in one year, on a business carrying nearly a quarter of group EBITDA. The group’s share of the NBN market has gone from around 23 per cent to around 18 per cent in three years, a relative decline of better than a fifth.

So the only disclosed movement in the business that houses iiNet is downward, and it is downward by more than a hundred thousand services.

Post #80 set out the mechanics. iiNet and Internode, two of the most trusted names in Australian broadband, consolidated, centralised, migrated and cost-optimised until the thing that made them worth choosing had been removed, at which point their customers went and chose something else. Aussie Broadband. Superloop. Launtel. Leaptel. The playbook TPG invented in the 2000s, run back against it by operators who execute.

Against that, iiNet’s complaints fell 23.6 per cent.

There is a version of a falling complaint count that reflects a company answering the phone. There is another version that reflects a company with fewer phones ringing. The TIO publishes the complaint. It does not publish the denominator, and it says so plainly: complaint numbers are not adjusted for the size of a provider’s customer base.

Nor, in this case, does the company. TPG discloses Fixed as one number, so no reader outside the building can divide iiNet’s complaints by iiNet’s customers and find out which version this is. The only figures available are a complaint count that fell and a subscriber line that fell further.

A company that loses more than a hundred thousand services and then reports fewer complaints has not demonstrated that it improved its service. It has demonstrated that it has fewer customers in a position to say otherwise.

One would like to call that a turnaround. On the published numbers, the honest word is attrition.

Eight quarters, one direction

The annual figure flattens something the quarterly reports show plainly. So here is the whole thing, two years of it, every provider that matters.

Quarter	Telstra	Optus	Vodafone	TPG	iiNet	TPG Group	All telcos
Jul-Sep 2024	5,131	3,124	1,297	502	441	2,240
Oct-Dec 2024	5,590	3,845	1,266	639	544	2,449
Jan-Mar 2025	5,823	3,587	1,319	846	531	2,696	15,385
Apr-Jun 2025	5,344 *	3,034 *	1,303 *	680 *	434 *	2,417 *
Jul-Sep 2025	5,184	3,207	1,363	604	372	2,339	13,547
Oct-Dec 2025	4,694	3,136	1,570	679	440	2,689	14,017
Jan-Mar 2026	4,623	3,208	1,501	636	388	2,525	14,002
Apr-Jun 2026	4,040 *	2,630 *	1,465 *	511 *	288 *	2,264 *	12,268 *
FY2025-26	18,541	12,181	5,899	2,430	1,488	9,817	53,834

* Derived by this masthead by subtracting the three published quarters from the published annual total. The method reconstructs each provider’s prior-year total to within a handful of complaints of what the Ombudsman’s own percentage changes imply, which is as much validation as an outsider can give it.

Read down the Vodafone column and the simplest fact in this article presents itself.

Every quarter of 2025-26 was worse than every quarter of 2024-25. The brand’s best quarter this year, 1,363, is higher than its worst quarter last year, and higher than its best. There is no overlap between the two years at all. Not one month of it.

The brand with nowhere to hide

Vodafone’s postpaid base did not shrink last year. It did not grow either. Post #80 and Post #94 have both set out the figure, and it has the dull perfection of a thing nobody can spin: 2,846,000 at the open of FY25, 2,846,000 at the close. Zero. Through a doubled coverage footprint rented from Optus at $143 million a year, forty million dollars of advertising, an American comedian on billboards across a country she does not live in, and a hundred days at half price.

And that is the flattering half of the picture, because underneath the postpaid line the traditional prepaid base went backwards: 1,732,000 services down to 1,702,000. Thirty thousand gone.

So the brand did not hold its ground. It held one line and lost thirty thousand services beneath it, taking the consumer on-net mobile base from 4,578,000 to 4,548,000.

Which means the denominator moved the wrong way at the same moment the numerator did. More complaints, from fewer customers. iiNet’s complaints fell into a shrinking base and TPG’s fell into a shrinking base, and both at least had the decency to fall. Vodafone’s rose 13.9 per cent into a base that was itself contracting.

That is not a denominator effect. It is the opposite of one, and it makes 13.9 per cent the kindest available reading of the year.

The quarter the instructions went out

For the four quarters to September 2025, Vodafone’s complaints sat in a narrow band. 1,266. 1,319. Around 1,303. 1,363. An average of 1,313 a quarter, give or take the ordinary noise of a large consumer business. Dull, stable, and on any reading the company’s own baseline.

Then October to December 2025, published by the Ombudsman in February 2026.

1,570 complaints. Up 24.0 per cent on the same quarter a year earlier, and up 15.5 per cent in three months.

Now hold that against what the market did in the identical quarter. Telstra fell 16.0 per cent. Optus fell 18.4 per cent. A forty-point swing against Telstra. Forty-two against Optus. Not a market cycle, not a seasonal effect, not an industry-wide shock, because the industry was travelling the other way, hard, at exactly that moment.

Nor was it confined to the one brand. TPG Group rose 14.1 per cent on the quarter. iiNet rose 18.3 per cent. The three together went from 2,339 complaints to 2,689, up 15.0 per cent in a quarter when the total national complaint count rose 3.5 per cent.

Which brings one to the other thing that happened in that quarter.

On 30 September 2025, the last day of the preceding quarter, which is to say one day of it, this campaign published its first video explaining the Telecommunications Industry Ombudsman process.

What it is, who it is for, that it costs nothing, and precisely how to lodge. It went wide.

A second followed inside the October to December quarter, and across that quarter the campaign’s TIO material reached close to half a million organic views. Not paid. Not amplified. People watching a short explanation of a complaints scheme they did not know existed, and then, in a number of cases they have since written in to describe, using it.

TPG is welcome to argue the two are unrelated, and this masthead asserts no causal link between them. Correlation is not causation and never has been, and the company’s own difficulties across that period, billing, the integration, the matters it declines to name, are ample explanation on their own.

But suppose, for the sake of argument, that the campaign were the whole explanation. Suppose every one of those additional complaints arrived because somebody learned that a free, independent ombudsman would look at their problem.

Then the position is this. The complaints were already there. The billing error was already there. The credit that never arrived was already there. The disputed debt referred to collection was already there. What was missing was not the grievance. What was missing was the knowledge that anything could be done about it.

A complaint is not created by telling somebody their rights. It is revealed.

Which means the only version of this in which TPG comes out ahead is the one where its customers remain unaware of a scheme it is obliged to tell them about. That is not a defence. It is a confession in a defence’s coat.

And it raises a question nobody has previously been in a position to ask with numbers attached. If half a million views can move the line this far, how large is the gap between the complaints Vodafone receives and the complaints Vodafone’s customers actually have?

The Ombudsman counts the people who found their way to the Ombudsman. Nobody has ever counted the ones who gave up.

The quarter everybody else fixed it

April to June 2026 was the best quarter the Australian telecommunications industry has had in years. The national complaint count fell by more than 1,700, down roughly 12.4 per cent in three months. Every major provider in the country went with it.

Telstra shed 583 complaints. Optus 578. TPG, the brand, 125. iiNet 100, a quarter of what it had.

Vodafone shed thirty-six.

In percentage terms that is 2.4 against Telstra’s 12.6, Optus’s 18.0, TPG’s 19.7 and iiNet’s 25.8, but the percentage flatters it. Thirty-six complaints is what a mid-sized retailer loses in a quiet week. Vodafone’s own stablemates, operating under the same group policies with the same board and the same outsourced contact centres, took a fifth and a quarter off their numbers in the same three months.

Vodafone took off thirty-six.

Three quarters since the spike, averaging 1,512 against a baseline of 1,313. Roughly six hundred complaints above the company’s own prior run rate, cumulative, in a year the industry came down by a fifteenth.

A spike is an incident. Three quarters is an operating level. And an operating level is a decision, whether or not anybody in that building has noticed making it.

Eighty point six per cent

Post #84 made this point and the annual report has done nothing to retire it.

The TIO reports Vodafone, TPG and iiNet as three separate providers, because that is how they are registered. Added together they come to 9,817 complaints, 18.2 per cent of every telco complaint made in Australia last year.

Now hold that against the two companies above them.

The group’s 9,817 complaints are 80.6 per cent of Optus’s entire total, across every service type Optus sells. They are 52.9 per cent of Telstra’s.

Optus carries roughly double TPG’s customer base. Telstra carries close to five times it.

Read that twice. On about half the customers, the TPG group generates four complaints for every five at Optus. On about a fifth of the customers, it generates more than half of everything Telstra’s entire national footprint produces.

Wholesale arrangements move those ratios at the margin and nobody should treat them as a precise per-customer index. They do not need to be precise. The gap is not a rounding question.

And 9,817 is a floor, not a ceiling, because it counts only the three group brands large enough to reach the top ten. Felix is in the group. Lebara is in the group. Neither appears, which is a sentence that reads rather less flatteringly the second time.

The disaggregation is not a trick. It is how the register works, and the Ombudsman is not in the business of consolidating anybody’s accounts for them. It is simply that the presentation happens to flatter, and nobody on the receiving end of that flattery has ever volunteered to add the lines back up.

So, as before: we have added them up.

What they got right

Credit where the data gives it, because the data does give some.

The fastest-growing complaint category in the country last year was unconscionable conduct, up 154.8 per cent to 553 complaints. Optus accounted for 69.8 per cent of those. Telstra 15.2 per cent. Vodafone 10.3 per cent.

On how customers are sold to, Vodafone is a distant third in a race nobody wants to win, and that deserves saying plainly and without qualification.

Nor is Vodafone the worst mover in the report. Superloop’s complaints rose 89.3 per cent to 1,418, and 108.3 per cent year-on-year in the March quarter alone. Lycamobile’s rose 303.9 per cent, carrying it from twenty-third place to ninth. Five of the top ten telcos recorded increases.

But Superloop and Lycamobile are growing hard off small bases, and growth of that kind breaks things in ways that are at least explicable. Vodafone is a mature brand inside a group whose other brands improved, backed by the most expensive network arrangement in the company’s history. The excuse available to the challengers is not available here. Vodafone is not buckling under the weight of new customers. There aren’t any.

Eleven months

There is one more thing missing from the picture, and it is not the Ombudsman’s fault.

Eleven months ago, TPG Telecom told the market that ACMA had commenced an investigation.

It did not say into what.

Eleven months later, it still has not. No scope. No subject. No indication of seriousness. No update, no resolution, no further mention. An acknowledgement offered and then immediately curtained off, which is the disclosure equivalent of clearing one’s throat and changing the subject.

And the investigation is not the only thing in those accounts left unexplained. A few lines away, the group’s “other” provisions did not tick up. They swelled from around $2 million to roughly $115 million in a single year, with some $118 million adjusted during the year. The attribution is a single clause: separation obligations arising from the Vocus transaction. Broadly.

That is plausible. Complex carve-outs throw off tail costs for years, and at roughly 2.5 per cent of a $4.7 billion deal the quantum sits comfortably inside the normal range. Taken at face value there is nothing untoward in it at all.

The difficulty is that it arrives as one line with no breakdown, which means no analyst outside the building can test it against its stated purpose. Uncertain amount, uncertain timing, one tidy explanation, and no working shown.

So: a regulatory investigation the company will not describe, and a hundred and fifteen million dollars the company will not itemise, in the same set of accounts, eleven months ago. Two curtains, one document. A reader is entitled to find the housekeeping consistent.

Post #84 noted that the same accounts carried a contingent liabilities note recording no matters expected to result in a material effect on the financial position. That remains a striking thing for a company with an open regulatory investigation to write down, and a striking thing for an auditor to read over.

One does not need to resolve whether the matter belongs in that note to observe that an investigation nobody will describe, now in its eleventh month, sitting beside a complaint line that rose 13.9 per cent while the industry fell, is a combination a careful reader is entitled to notice.

Companies confident the explanation is innocent generally furnish it. This one would be so easy to give.

Prospectively

And now the part that makes all of the above considerably more interesting, because it has stopped being a customer-service question and become a pay question.

TPG tells the public, on its own sustainability pages, that the Complaints in Context ratio, TIO complaints per 10,000 services, is “a key metric that we hold ourselves accountable to.” Fine words, and until recently that is all they were, because accountability of that kind costs nothing and appears on no scorecard.

Post #91 set out what the scorecard actually rewarded. For the year ended 31 December 2025, the chief executive collected a short-term incentive of $3,053,206, being 87.64 per cent of the maximum available, from a business that cleared some seven million dollars, on an underlying basis, before tax on revenues in the billions. The customer measure on that scorecard was a Net Promoter Score the company marks itself, and it printed at maximum, in the year the Ombudsman’s tables printed at a multi-year worst.

A satisfaction measure the company grades itself, paying out at full marks, in the year the external measure fell over. One assumes the two methodologies simply disagreed.

Then the scorecard changed. In the Notice of Annual General Meeting, the company disclosed it in a single sentence:

“2026 STI plan measures remain consistent except for the inclusion of a Customer Wellbeing measure.”

For 2026. Going forward.

Not for 2025, the year the self-marked measure paid at maximum against an ombudsman record that did not support it. Not for 2024. Prospectively only, which is the direction in which remuneration reform in this country reliably travels.

One can admire the timing without admiring much else.

It is worth being precise about what the new measure is denominated on. The Complaints in Context ratio is complaints per 10,000 services in operation. Not complaints. The ratio.

Which means it deteriorates two ways: when complaints rise, and again when services fall. Vodafone is currently doing both.

Run it. Around 11.3 complaints per 10,000 consumer services last year. Around 13.0 this year. A deterioration of roughly 15 per cent against a complaint rise of 13.9, and the gap between those two numbers is thirty thousand prepaid customers who are no longer there to be counted underneath.

A brand shedding services while adding complaints is moving both halves of its own bonus metric in the wrong direction at once. Somebody selected that measure. One wonders whether anybody modelled it.

Because here is what it means in practice. The first year in which customer wellbeing affects what senior executives are paid is the year now running. And the Ombudsman’s annual report already contains six months of it: January to March at 1,501 complaints, April to June at a derived 1,465. Two thousand, nine hundred and sixty-six complaints in the first half of the first year the measure counts. That is not lower than the half before it. It is marginally higher. In six months when the rest of the industry fell off a cliff.

The conversation inside that building is now a different conversation. It is no longer “customer care needs to improve”, which is the sort of sentence that survives a town hall and three quarterly reviews without anybody having to do anything. It is “this number is on the scorecard the board uses to pay us, and it is the only one in the sector going the wrong way.”

A remuneration committee does not much care where the complaints came from. It does not care which process broke, which vendor underperformed, or which quarter the integration landed in. It cares that the metric is not improving.

And if management has previously told that board, as it has told the market repeatedly for three years, that Australian-based support has been increased, that stores have been improved, that processes have been changed, that customer experience has been invested in, then a year in which Telstra took off 583 complaints and Optus 578 and iiNet a quarter of its book and Vodafone took off thirty-six invites the question that has no comfortable answer:

Where are the results?

That question now has a dollar value attached. One looks forward to February.

Five providers, unnamed

The Ombudsman opened 47 systemic investigations during the year and closed 37, the majority of which it says produced changes by the provider concerned.

Five providers were referred to regulators.

The report does not say which five. It does not have to. But anybody who has read the top-ten table is now holding a short list and a long year, and the companies on that list are considerably better informed than the rest of us about which of them is on it.

Post #84 observed that the TIO’s Systemics team exists precisely to notice when complaint themes stop being individual gripes and start looking like a process failure, and that it can refer what it finds to ACMA.

Forty-seven investigations opened. Five referrals out the door. One ASX-listed company sitting on an undisclosed ACMA investigation now in its eleventh month.

No connection is asserted between those facts. They are simply all true at once, which is a different thing, and the reader is permitted to hold them simultaneously.

The queue at the Ombudsman

And now the part that ought to trouble everybody, the Ombudsman included.

The TIO closed 50 per cent of escalated cases within 60 days, against its own target of 75 per cent. Its customer satisfaction came in at 79 per cent against a target of 87. Member satisfaction, the telcos’ view of the umpire, slipped from 64 to 62, which one suspects is not a complaint about leniency.

So complaints went down, and the time taken to deal with the hard ones went up.

That is the experience most people actually have. The front end of the machine works well enough: over 70 per cent of complaints resolve the moment the TIO hands them back to the provider with a reference number attached, which tells you something fairly bleak about what the provider was doing with them before the reference number arrived. It is the matters that survive that first bounce, the ones where the telco has already declined to fix it once, formally, in writing, to an ombudsman, that enter the slow part.

Half of those now take more than two months.

The scheme is not failing. It is carrying a load it was not built for, from an industry that has worked out it can push the cost of its own complaint handling onto a body funded by the industry and staffed by somebody else.

Every complaint resolved at first referral is a complaint the telco could have resolved itself, at its own cost, before it became anybody else’s problem. Seventy per cent of them.

The letters keep coming

Which brings this to the part that is not a table.

This campaign still receives messages and comments every week from Vodafone customers. They are not writing about the annual report, which most of them will never read, and they are not writing about ARPU or EBITDA or the remuneration report.

They write to ask how the TIO process actually works.

What a referral is. Whether a conciliation is a meeting and whether they have to attend. Whether they can complain while a debt is being chased, and whether complaining will make the debt worse. What to do when a credit promised on the phone never appears on the bill. What to do when the fourth agent gives the third answer. Whether there is any point.

The same questions, from different people, every week, for years.

There is something genuinely odd about being the place Australians come for instructions on how to use a free, independent complaints scheme that exists specifically to help them, that costs them nothing, and that their own provider is obliged to tell them about. The obligation exists. The instruction apparently does not travel.

Complaints fell 6.5 per cent across the industry last year and that gap did not close by an inch.

So, plainly, for anybody who has arrived here looking for it:

The TIO is free. It costs you nothing, ever. It is independent of your telco and is not part of it, whatever the agent on the phone implies.

You can use it once you have given your provider a reasonable chance to fix the problem. You do not need a lawyer, a case number, a transcript, or a particularly good day. You need your account number and a short description of what went wrong and what you want done about it.

You can complain while a debt is in dispute. Lodging a complaint about a disputed amount is precisely what the scheme is for, and a provider referring a disputed debt to collection while a TIO matter is open is a thing the Ombudsman wants to hear about.

Write down what you were promised, and when. The single most common failure in the messages this campaign receives is a credit or waiver agreed verbally and never applied. Dates and names beat recollection every time.

If it does not resolve at referral, it escalates. That is the slow part, and now the slower part, but it is also the part where the provider has to put its position in writing to somebody other than you.

The Fight page on this site sets the whole thing out, step by step. It has been there for years. It should not have to be.

What the scoreboard actually says

Strip out the commentary and the eight quarters say this.

The industry improved, and in the final quarter it improved dramatically. The two largest carriers improved substantially off vastly larger bases. Two of TPG’s three brands recorded fewer complaints, both of them out of a fixed-line business that shed more than a hundred thousand services, and neither of them in a way any outsider can separate from the customers who left. And the brand carrying the group’s name into the mobile market, the one with the rented regional network and the forty million dollars of advertising and the comedian, posted four consecutive quarters each worse than any quarter of the year before, lost thirty thousand prepaid services underneath, and then declined to participate in the recovery.

Nine thousand, eight hundred and seventeen complaints across three tidy lines. Eighty point six per cent of Optus’s total on half the customers. Fifty-two point nine per cent of Telstra’s on a fifth. Six hundred complaints clear of the company’s own baseline. Eleven months into an investigation nobody will describe.

Post #94 described a company no longer arguing about how to win, because there is no available way to win, but about which way to lose. The Ombudsman’s annual report is the external audit of that argument and it has returned the same answer it returned last quarter, and the quarter before, and the quarter before that.

The company’s own customer score, for the same year, printed at maximum.

Full marks.

Right of Reply

TPG Telecom Limited, Vodafone Australia, iiNet, Felix, the Telecommunications Industry Ombudsman, the Australian Communications and Media Authority, and any individual or entity who considers themselves referenced in this article are warmly invited to correct, clarify or add context to anything set out above, including any figure or characterisation. If a number is wrong, a date misremembered, a derived quarterly figure differently calculated, or the subject of the ACMA investigation disclosed since this went up, the author would like to know and to say so.

This right of reply remains open indefinitely, rather less time, one notes, than the company has so far taken to say what the regulator is looking at.

Disclosure, Disclaimer and Legal Notice

This article is independent commentary and analysis on a matter of public interest, drawn entirely from publicly available material: the Telecommunications Industry Ombudsman’s Annual Report 2025-26 and its published quarterly Complaints Data Insights reports; TPG Telecom’s ASX disclosures, annual report, remuneration report, Notice of Annual General Meeting, investor presentations, sustainability and customer wellbeing pages, and reported subscriber, ARPU, market-share and guidance figures; publicly reported competitor figures and transactions; publicly posted discussion on consumer forums; and correspondence received by this campaign from members of the public. No confidential, privileged or non-public information has been used in its preparation.

Complaint data. All provider complaint counts and percentage changes attributed to the Ombudsman are as published by the Ombudsman in its annual and quarterly reports. As the Ombudsman itself states, complaint numbers are not adjusted for the size of a provider’s customer base, and the making of a complaint is not a finding of fault against any provider. Quarterly and annual reports may be compiled on differing bases, and the Ombudsman has previously published restated figures; readers should treat any comparison across reports accordingly.

Derived figures. Figures identified in the text as derived are this masthead’s own arithmetic, obtained by subtracting published quarterly figures from published annual totals, or by applying published quarter-on-quarter percentages to published counts. These include the April to June 2025 and April to June 2026 quarterly figures for each provider, the April to June 2026 national total, the four-quarter baseline average and the three-quarter average following it, the cumulative excess above that baseline, the combined TPG group totals and the ratios expressed against Optus and Telstra, the relative NBN market-share decline, the first-half 2026 total, and the complaints-per-10,000-services ratios, which are calculated on the company’s reported consumer mobile services and may differ from the Complaints in Context ratio as computed by Communications Alliance on a provider’s full services in operation. As a check on method, the same approach reconstructs each provider’s 2024-25 annual total to within a handful of complaints of the figure implied by the Ombudsman’s own published year-on-year change; that is validation of the arithmetic only, and the derived figures remain this masthead’s estimates rather than published data. The aggregation of brand-level complaint figures into a group total reflects publicly reported corporate ownership and is presented as analytical commentary, not as a figure published by the Ombudsman.

Customer-base comparisons. Subscriber and market-share figures are drawn from public reporting and published estimates and are subject to the limitations of external estimation. Wholesale and MVNO arrangements affect how services are attributed between providers. Comparisons of complaint volumes against customer bases are offered as order-of-magnitude observations and are expressly not a precise per-customer index.

This campaign’s material. References to the reach and timing of this campaign’s published explanation of the Telecommunications Industry Ombudsman’s process, set against published complaint data, are two separate sets of facts placed side by side. No causal relationship is asserted or implied between any material published by this campaign and the complaint volumes recorded against any provider. Correlation is not causation. The Ombudsman’s figures record complaints made by consumers on their own initiative about their own circumstances, and this masthead makes no claim as to why any individual complaint was made. Nothing here should be read as suggesting that any complaint recorded by the Ombudsman was other than a genuine complaint made by a consumer about a matter of concern to them. View figures for this campaign’s material are as reported by the relevant platform.

Consumer correspondence. Descriptions of messages and comments received by this campaign are general characterisations of correspondence received over time. No individual correspondent is identified and no confidential information provided by any correspondent is disclosed. Those who write in are self-selecting; they are not a representative sample of any provider’s customer base, and nothing here should be read as suggesting their experiences are indicative of that base as a whole. Forum and social media comments referred to are the publicly posted opinions of their respective authors, reproduced for comment and analysis, and are individual accounts cited as such.

Information about the TIO process. The general information set out in this article about how the Telecommunications Industry Ombudsman scheme operates is provided for public information only, reflects this masthead’s understanding of the scheme as publicly described by the Ombudsman, and is not legal advice. Readers should refer to the Ombudsman directly at tio.com.au for guidance on their own circumstances.

Remuneration and incentives. References to executive remuneration, short-term incentive outcomes, scorecard measures and the timing of changes to those measures are drawn from TPG Telecom’s own published remuneration report, Notice of Annual General Meeting and related disclosures, and are stated as disclosed. The quoted sentence concerning 2026 short-term incentive measures is reproduced from that Notice. The description of the Complaints in Context ratio as a metric the company “holds itself accountable to” is TPG Telecom’s own published wording. Commentary on incentive design, on the likely behavioural consequences of particular measures, and on the character of discussions such measures may prompt at board or committee level is analytical opinion and reasonable inference drawn from publicly observable behaviour and published disclosure. It is not an allegation of impropriety, bad faith, manipulation or breach of duty by any director, officer, employee or committee, and no assertion is made about the content of any internal document, meeting or communication. No information has been sought or obtained from any person subject to a duty of confidence.

Regulatory matters. References to an investigation commenced by the Australian Communications and Media Authority, and to the absence of further detail about it, reflect what the company has itself disclosed to the market and what it has not. No assertion is made as to the subject, scope, seriousness or likely outcome of that or any other investigation, nor that any provider has breached any law, regulation, code or standard. References to the Ombudsman’s systemic investigations and to referrals made by it to regulators are as published by the Ombudsman, which does not identify the providers concerned; this masthead does not identify them either, and no inference should be drawn that any particular provider is among them. Commentary on the treatment of regulatory matters in the company’s contingent liabilities note is analytical opinion as to disclosure practice and is not an assertion that any accounting standard, auditing standard or legal obligation has been breached by the company, its directors or its auditor.

Characterisations and inference. Characterisations of the company’s strategic position, trajectory, customer experience, complaint-handling performance and prospects, including references to decline, attrition, pressure, internal tension and any future consolidation, are the author’s opinion and analytical inference, reasonably held on the basis of the public material identified above, and are offered as commentary. They are expressly not statements of fact as to solvency, viability or future performance, nor as to the intentions of any company, shareholder or director. Nothing here asserts that TPG Telecom is insolvent, unable to meet its obligations, at risk of failure, or in negotiations of any kind.

All views expressed are the author’s honest opinions, formed on reasonable grounds from that public material, and are published in reliance on the protections afforded to honest opinion, fair comment, and publication in the public interest under the Defamation Act 2005 (NSW) and its state equivalents. No allegation is made, and none should be read, that TPG Telecom Limited, Vodafone Australia, iiNet, Felix, Lebara, the Telecommunications Industry Ombudsman, the Australian Communications and Media Authority, any other provider named, or any related entity, director, officer or employee has engaged in misleading conduct or any breach of any law, regulation, code or standard. All entities and individuals retain the presumption of lawful conduct unless a competent authority determines otherwise.

This is not financial, investment or legal advice, and nothing in it constitutes a recommendation to buy, hold or sell any security, or to switch to or away from any provider. TPG Telecom, Vodafone, iiNet, Internode, Felix, Lebara, Optus, Telstra, Superloop, Aussie Broadband, Launtel, Leaptel, Lycamobile and related names and logos are trademarks of their respective owners, used here for identification, commentary and analysis only, with no affiliation, sponsorship or endorsement asserted or implied.

The author has an active dispute with TPG Telecom Limited (ASX: TPG), has made protected disclosures under Part 9.4AAA of the Corporations Act 2001 (Cth), and holds an immaterial shareholding in TPG Telecom Limited. The author also operates public consumer-advocacy channels concerning Vodafone Australia, including the material referred to in this article. These interests should be weighed when reading this commentary.

The author has taken reasonable steps to ensure the accuracy of the information presented. If any factual matter is incorrect, the author welcomes correction and undertakes to amend the article promptly upon verification.

Previous posts in this series:

Post #65 – When The Music Stops

Post #66 – The $2B Problem TPG Can’t Afford

Post #67 – The Bonus Year: Thin Earnings, Thick Optics

Post #68 – Buying the Narrative

Post #69 – The Smart Money Just Left the Building

Post #70 – Who’s Watching the Watchers?

Post #71 – Nine Lives

Post #72 – Marked Safe from the Whistleblower Policy

Post #73 – The Story Nobody Will Publish

Post #74 – Nothing Out Here

Post #75 – The Gift That Keeps Giving