Existing regulatory frameworks cover D2D
Australian Communications and Media Authority (ACMA)
a. D2D in MSS bands
MSS can operate in frequency bands already allocated in the International Telecommunications Union (ITU) Radio Regulations and the Australian Radiofrequency Spectrum Plan. Mobile handsets, including satellite phones, that are capable of operating in the MSS frequency bands are licenced under the Radiocommunications (Communication with Space Object) Class Licence 2025 (CSO class licence). The CSO class licence allows operation of an earth station (e.g. a D2D-enabled handset or satellite phone) to communicate with a licensed space station listed on the Australian Space Objects Determination (ASOD) or Foreign Space Objects Determination (FSOD) (collectively the Space Objects Determinations). Satellite operators must also obtain the relevant apparatus licences (space licence and space receive licence) from the ACMA.
A CSO class licence allows operators to use common radio equipment on shared frequencies without requiring an individual application or fees, subject to the conditions under the Radiocommunications Act 1992.
In practice, this means that existing satellite phones can already operate and provide D2D services in the MSS frequency bands. As the technology continues to evolve, newer handsets with MSS capability are expected to operate under the CSO class licence.
b. D2D in mobile bands
The ACMA takes the view that the operation of D2D services in mobile bands is regulated under Australia’s pre-existing spectrum licensing regime. The onus is on D2D service providers and their partner spectrum licence holders (i.e. the MNO) to ensure that the service is compliant with relevant spectrum licensing regulations and the ITU Radio Regulations.
Ordinarily, satellite operators would need to apply to be listed on the Space Objects Determinations (as stated above). However, the frequency bands contemplated for IMT services (which enable D2D services without additional hardware) are not currently within the scope of the Space Objects Determinations for licensing purposes. Therefore, D2D service providers operating within the mobile bands are not required to apply for inclusion in the ASOD or FSOD.
Spectrum licences are usually granted via an auction process after consultation with the ACMA and Australian Competition and Consumer Commission (ACCC). These licences allow service operators to operate over a specific geographical area (which may be Australia-wide) and at a specified frequency, to avoid interference with other services.
In practice, this means that D2D services in mobile bands can only operate in agreement with an MNO which holds a spectrum licence. Operating without such an agreement would risk complaints to the ACMA for interference with the MNO's spectrum licence.
In September 2025, following an initial proposal earlier in the year, the federal government released draft legislation setting out the Universal Outdoor Mobile Obligation (UOMO). The Telecommunications Legislation Amendment (Universal Outdoor Mobile Obligation) Bill 2025 (Cth) (UOMO Bill) would require Optus, Telstra and TPG (Australia’s national mobile carriers) to ensure that baseline outdoor mobile coverage is reasonably available across Australia on an equitable basis.
The UOMO Bill does not specify what technology should be used to provide this service, but it is expected that MNOs will use D2D technology, provided via low earth orbit satellites.
