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Optus is looking for a cleaner delineation on when it needs to send a notice under Australia's Telecommunications Sector Security Reforms[1] (TSSR) after noting it accounted for half the notices sent so far under the regime.

Under the TSSR, carriers need to "do their best" to protect their networks from unauthorised access or interference for the purpose of security, with carriers to notify the government of any changes to their services, systems, or equipment that could have a "material adverse effect" on their ability to comply with this duty.

In a submission to the Parliamentary Joint Committee on Intelligence and Security (PJCIS) which is reviewing the TSSR, Optus noted that over the two-year period to June 30, the Critical Infrastructure Centre received 66 notifications in total, which meant it completed half the notices.

"Optus has reviewed the TSSR status of well over 150 projects and proposed changes over the last two years and submitted formal TSSR notifications for 36 of them," it said.

"The time for the resolution of these notifications has varied between 30 days to eight months."

The telco said this meant the regime was not operating as intended due to telcos each coming up with their own notification thresholds and interpretations. Consequently, the TSSR is simultaneously at risk of under-notification and over-notification.

"This uncertainty means that it is highly unlikely that providers are implementing the rules in the same way within their organisations, creating an unequal playing field for providers," it said.

"Due to the confidential nature of the TSSR notifications, it is difficult for providers to engage in detailed industry discussions on this topic to ensure a consistent application of the rules.

"If the TSSR notification provisions are retained, Optus

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