Is the Australian RCM enough to activate a cellular IoT device on Telstra?

It is the legal floor, not the carrier step. A cellular device is customer equipment, so on top of radio and EMC it must meet the Telecommunications (Mobile Equipment Air Interface) Technical Standard 2022 (AS/CA S042.1, plus S042.4 for LTE and S042.5 for 5G) and be labelled under the Telecommunications Labelling Notice 2025. Telstra says RCM certification is the main requirement to connect to any Australian mobile network, and its IoT/M2M certification is a separate interoperability test that it strongly recommends, run after the regulatory step. The costs are set in a Device Testing and Certification Agreement and paid by the manufacturer.

Which bands does Telstra require for a new IoT device?

Telstra list of certified modules (published 30 January 2026) sets the minimum: 5G bands n78, n7 and n26; 4G bands 7, 28 and 3; LTE-M and NB-IoT on Band 28; 5G RedCap on n26. Band 28 is the 700 MHz APT plan, which a module built only for US 700 MHz bands (B12, B13, B17) does not cover. Band 5 does not appear in that minimum list.

Is 3G still available in Australia?

No. TPG Telecom (Vodafone) switched off its 3G network on 15 December 2023. Telstra closed its 3G network from 28 October 2024, and Optus began its staged shutdown the same day. Telstra now says 2G and 3G shall not be enabled when a device is on the Telstra network, though they may be enabled when roaming overseas. New devices must use 4G and 5G, with VoLTE or VoNR if they carry voice.

Will a data-only IoT device be blocked under the Triple Zero rules?

Not under the emergency call blocking duty itself. Since 28 October 2024, Part 4 of the Telecommunications (Emergency Call Service) Determination 2019 requires providers to identify mobile phones that cannot reach 000 and to stop supplying them. The Determination defines a mobile phone as a handheld device capable of voice communications and expressly excludes fixed broadband gateways, internet of things devices, personal alert devices, smartwatches and tablets. A voice-capable device sold in Australia must still meet the emergency call requirements of AS/CA S042.1.

How long does Telstra certification take?

Telstra gives 2 to 4 weeks of testing for a device built on an approved module and 6 to 8 weeks for a device on a non-certified module, subject to the defects found during testing. TPG Telecom gives about 4 to 6 weeks for its IoT Device Assurance Program when the device uses an approved IoT module and no issue appears in pre-acceptance testing. These are test durations, not the administrative steps before them.

What does Telstra publish about eSIM and eUICC?

Its certification documents do not set eUICC requirements: no GSMA SGP.32 mandate, no SAS-UP requirement and no SGP.02 retirement date appear in them. The GSMA architecture to discuss with the carrier is SGP.32 for IoT, which adds the eSIM IoT remote Manager (eIM) and the IoT Profile Assistant (IPAd in the device or IPAe in the eUICC), alongside SGP.22 for consumer devices and SGP.02 for legacy M2M.

Are PTCRB or GCF certifications recognised by Australian carriers?

None of the published Telstra or TPG documents makes PTCRB or GCF a condition or a substitute for their own testing. Telstra appears on the GCF list of Field Trial Qualified networks, which means GCF member manufacturers can run GCF field trials on its network. What the carrier will reuse from a PTCRB or GCF campaign is decided case by case with that carrier.

Telstra, Optus, TPG: cellular IoT acceptance in Australia

Hugues Orgitello updated 7 Oct 2026 11 min read

A cellular IoT device sold in Australia passes two gates. The first is regulatory: the device is customer equipment under the Telecommunications Act 1997, so besides radio and EMC it must meet the Mobile Equipment Standard 2022 (AS/CA S042.1 and its LTE and 5G parts) and carry the RCM under the Telecommunications Labelling Notice. The second is the carrier: Telstra runs an IoT/M2M certification program with a published band minimum, TPG Telecom runs an IoT Device Assurance Program on the Vodafone network, and Optus advertises accelerated device certification support. Between the two sits the 3G closure of 2023 and 2024 and the Triple Zero rules that followed it, which explain why Telstra now forbids 2G and 3G on its network. This page rebuilds the stack from the Telstra documents and the instruments on the Federal Register of Legislation, as of 7 October 2026.

Regulator and carrier, two distinct layers

The RCM side is described in ACMA and RCM. For a cellular product, the part most guides skip is telecommunications. The Radiocommunications (Cellular Mobile Telecommunications Devices) Class Licence 2024 authorises a device to talk to a mobile base station, but section 11 makes that authorisation conditional: a person must not operate a device that is customer equipment unless the manufacturer or importer has met the telecommunications labelling requirements and the device complies with the technical standards made under section 376 of the Telecommunications Act. A non-compliant cellular module is therefore not only unlabelled, it is operated without a licence. Since 3 July 2026, a variation of the class licence also adds section 12: a device operated in the 1900 to 1910 MHz band must not exceed a total radiated power of 31 dBm/10 MHz and must use transmit power control.

Layer	Who sets it	Instrument	Output
Radio, EMC, EME	ACMA	Radiocommunications Act 1992, Equipment Rules 2021, EMC Standard 2017 with AS/NZS CISPR editions, Cellular Mobile Class Licence 2024	RCM, records, registration on the national database
Telecommunications	ACMA, with Communications Alliance standards	Mobile Equipment Standard 2022 (AS/CA S042.1, S042.4, S042.5), Telecommunications Labelling Notice 2025	RCM, declaration of conformity, evidence of compliance
Emergency calls on the network	ACMA, applying to carriers and providers	Emergency Call Service Determination 2019, Part 4 (since 28 October 2024)	Providers identify and stop supplying mobile phones that cannot reach 000
Carrier acceptance	Telstra, TPG Telecom, Optus, separately	Carrier programs and agreements	Telstra Technical Approval and listing; TPG device network certification

Telstra put the order in writing as early as its 2015 guidelines: its certification "is an activity that takes place only after ACMA RCM/A-Tick certification is met", and RCM is "the main requirement" to connect to any Australian mobile network.

The telecommunications layer, by device type

The Mobile Equipment Standard 2022 applies to customer equipment designed for a public mobile telecommunications service (or a satellite service) that is an addressable device. Its section 8 lists the applicable industry standards: AS/CA S042.1 in all cases, AS/CA S042.4 for 3G and 4G, AS/CA S042.5 for 5G. The Labelling Notice 2025 then decides how strong the evidence must be, and it splits mobile equipment in two.

Point	Data-only IoT device (no standard telephone service)	Voice-capable device (standard telephone service)	Source
Labelling Notice 2025, Schedule 1 item	Item 3	Item 2	TLN 2025, Schedule 1
Applicable technical standard	Mobile Equipment Standard 2022	Mobile Equipment Standard 2022	TLN 2025, Schedule 1
High risk standard	None listed	Each part relating to AS/CA S042.1	TLN 2025, Schedule 1, column 4
Evidence before signing the declaration of conformity	A statement by a certification body or a test report (any kind of document may be relied on)	For the S042.1 parts: an endorsed test report (accreditation body mark) or a statement prepared by a certification body	TLN 2025, section 22(4)
Emergency call initiation (000 and 112)	Applies to equipment "designed for voice communications"	Must allow an emergency call; 000 and 112 stored in firmware; emergency call possible without an identity module	AS/CA S042.1:2025, clauses 5.1.1 and 5.2.2.1
Blocking duty of Determination Part 4	Excluded: internet of things devices are not "mobile phones"	Applies if the device is a mobile phone in the Determination sense	ECS Determination 2019, Part 4

Two more rules matter to manufacturers. Before supplying an item, the manufacturer or importer must be registered on the national database (TLN 2025, section 20). And the standard follows the item over time: a software update made by or for the manufacturer creates a "modified item" (Mobile Equipment Standard, section 6), and the TLN requires a written statement of whether the modification is material before supply (section 23).

AS/CA S042.1:2025 was published on 30 June 2025. Its stated aim is to update the emergency call requirements and to add Emergency Cell Broadcast support for the National Messaging System. Under section 9 of the Mobile Equipment Standard, a replacement standard opens a 12-month transition period from its publication date, which the standard itself confirms for S042.1:2022.

3G closures and the Triple Zero rules

Date	Event	Source
15 December 2023	TPG Telecom (Vodafone network) switches off 3G	TPG 3G closure FAQ; AMTA fact sheet
March 2024	AMTA still lists Telstra for 30 June 2024 and Optus for September 2024	AMTA fact sheet
6 May 2024	Telstra extends its closure to 28 October 2024	Telstra
23 October 2024	ACMA makes the Emergency Call Service Amendment Determination 2024 (No. 1), registered the next day	F2024L01353
28 October 2024	Telstra closes its 3G network; Optus starts its staged shutdown; Part 4 of the Determination commences	Telstra; ACS Information Age; F2024L01353, section 2
2 November 2024	From this date providers must identify phones that are no longer able to reach 000 (sections 68 and 69)	ECS Determination 2019
1 November 2025	Compilation No. 4 of the Determination	Federal Register of Legislation

For a mobile phone found unable to reach 000 after 2 November 2024, the provider must notify the user within 5 business days, send two more notices, and stop supply between 28 and 35 days after the first notice (section 69). The check covers both the provider network and, if it is unavailable, the networks of other providers. That is why the S042.1 emergency call clauses, and VoLTE emergency calling, became a hard market condition for voice products after the 3G closures.

For IoT, the decisive text is the definition. The Determination defines a mobile phone as a handheld mobile device capable of voice communications, and excludes devices "not ordinarily considered to be a mobile phone such as" fixed broadband gateways, internet of things devices, personal alert devices, smartwatches and tablets. A sensor or tracker on an IMEI range is therefore outside the blocking duty, which does not exempt it from the Mobile Equipment Standard.

Telstra IoT/M2M certification

What Telstra publishes

Telstra defines its IoT/M2M device interoperability testing as "a cellular network certification and validation process" to ensure devices are interoperable with its mobile network, and it "strongly recommends" that module and device manufacturers certify. The current list, published on 30 January 2026, sets these rules:

2G and 3G "shall not be enabled" when on the Telstra network (they may be when roaming overseas).
New IoT/M2M devices must support 4G, 5G Standalone, and VoLTE or VoNR if voice is required.
5G Reduced Capability (RedCap) is enabled on the network for low data rate use cases; Telstra advises 5G Standalone devices where product longevity matters.
Telstra is mandating IPv6 support for IoT and M2M devices in 2026.
Integrated devices using a certified module must run the Telstra certified firmware version of that module.
All certified modules and devices must support remote firmware upgrade.

The band minimum

Technology	Bands Telstra requires as a minimum	Notes
5G NR	n78, n7, n26	n78 is 3.5 GHz; n26 is the 850 MHz range
4G LTE	Band 7, Band 28, Band 3	Band 28 is the 700 MHz APT plan
LTE-M and NB-IoT	Band 28	The only LPWAN band in the list
5G RedCap	n26

Two consequences for a European design. Band 28 is the band that a module built only for the US 700 MHz bands (B12, B13, B17) does not have. And the list contains no mmWave band: a 26 GHz (n258) radio is not part of the Telstra minimum for IoT.

Process, time and cost

Telstra describes six steps: engagement through an enquiry form, pre-submission exchange of documents, "ranging" (an iterative review of the documentation), testing with the manufacturer in the Telstra Lab, approval ("Technical Approval is issued"), and maintenance, during which any hardware or software update must be communicated to Telstra so it can decide whether re-certification is needed.

Point	What Telstra says
Testing time, device on an approved module	2 to 4 weeks
Testing time, device on a non-certified module	6 to 8 weeks
Condition	"Subject to the defects identified during the testing period"
Costs	Set in the Device Testing and Certification Agreement and paid by the IoT/M2M device manufacturer
Finished device without a certified module (2015 guidelines)	Both the module and the finished device undergo separate testing
Contact	telstrawirelessm2mhardware@team.telstra.com

The 2015 guidelines added that Telstra selects which devices it certifies based on criteria aligned with its M2M strategy, with a logo "Certified for Use on the Telstra Network". They described a co-funding model; the current page says the manufacturer pays.

What the module list shows

The certified list mixes 5G modules (many marked NSA, the newer ones SA), LTE categories from Cat 1 to Cat 20, LTE-M and NB-IoT modules, and integrated devices such as water meters and vehicle trackers. Many older entries still declare 3G support: these were certified before the closure, and the 2026 rule is that 3G must not be enabled on the Telstra network. Choosing a listed module and the listed firmware is the documented way to the shorter 2 to 4 week test.

TPG Telecom and Optus

TPG Telecom runs the IoT Device Assurance Program for the Vodafone Australia network. It "pressure tests" the ability of a device to connect and interoperate, with testing by its internal device testing team and a Sydney based lab partner, in two phases starting with pre-acceptance testing. TPG states about 4 to 6 weeks when the device uses an approved IoT module and pre-acceptance raises no issue, and lists 4G LTE, 5G and NB-IoT as the technologies covered. It also states that device network certification checks compliance with ACMA requirements.

Optus does not publish an equivalent certification document. Its IoT Starter Kit page offers "accelerated device certification" as part of developer support. Ask Optus for its current requirements before planning a campaign.

PTCRB and GCF

PTCRB is the North American scheme and GCF the global one; see PTCRB and GCF compared. No Telstra or TPG document reviewed here makes either a prerequisite or accepts it in place of carrier testing. One link exists: Telstra is on the GCF list of Field Trial Qualified networks, so GCF field trials for member manufacturers can run on the Telstra network. The 3GPP conformance results from a GCF or PTCRB campaign remain useful evidence to discuss with the carrier.

eSIM and remote provisioning

The GSMA defines three remote SIM provisioning architectures: GSMA SGP.02 for M2M, GSMA SGP.22 for consumer devices with a user interface, and GSMA SGP.32 for IoT. SGP.32 introduces the eSIM IoT remote Manager (eIM), which orchestrates profile download, enable, disable and delete for headless devices, and the IoT Profile Assistant, located in the device (IPAd) or in the eUICC (IPAe). Telstra and TPG certification documents do not set eUICC requirements, so profile management is a point to agree with the connectivity provider, not a published acceptance criterion.

Claims the texts contradict

Claim (including in the earlier version of this page)	What the text says
"Telstra finalised its 3G shutdown in August 2024, followed by Optus and TPG"	TPG closed first, on 15 December 2023. Telstra closed from 28 October 2024, and Optus began the same day
"Uncertified IoT devices can be blocked at TAC level under the emergency call rules"	Part 4 of the ECS Determination targets "mobile phones", a definition that excludes internet of things devices and fixed broadband gateways
"The RCM covers radio, EMC and electrical safety"	A cellular device is also customer equipment: Mobile Equipment Standard 2022 and Labelling Notice 2025 apply, and the class licence makes operation conditional on them
"B5 850 MHz is central to Telstra; LTE-M and NB-IoT run on B5 and B28"	Telstra minimum: LTE-M and NB-IoT on Band 28; 4G on Bands 3, 7, 28; the 850 MHz range appears as 5G n26. The old 3G850 network is closed
"Acceptance rests on a Telstra MoU test plan"	Telstra refers to a Device Testing and Certification Agreement, with costs paid by the manufacturer
"Telstra requires a SAS-UP eUICC and treats SGP.02 as end-of-life"	No such requirement appears in the Telstra certification documents
"SGP.32 introduces the eSIM IoT Manager"	The GSMA role is the eSIM IoT remote Manager (eIM)
"Foreign manufacturers get a Supplier Code Number"	The TLN 2025 requires registration on the national database by the manufacturer or importer; see ACMA and RCM
"Each Australian carrier keeps its own approved IMEI list"	Not stated in the carrier documents reviewed; Telstra publishes a list of certified modules and devices, not of IMEIs

Project sequencing

Pick a module that covers the Telstra minimum (Bands 3, 7, 28; LTE-M and NB-IoT on Band 28; n78, n7, n26 if 5G) and that appears on the Telstra certified list with its firmware version.
Decide whether the product supplies voice. A voice-capable product moves to the high risk S042.1 regime and must meet the emergency call clauses; a data-only product does not.
Build the RCM file with radio, EMC, EME and the telecommunications evidence, register on the national database, sign the declaration of conformity.
Contact Telstra (and TPG or Optus if targeted) through their enquiry channels, then test. Keep 2G and 3G disabled for the Australian network and plan IPv6.
After launch, report every hardware or software update to the carrier, and record for the TLN whether each modification is material.

For overall timing see Certification timeline and Certification costs.

Key takeaways

The RCM for a cellular device includes the telecommunications layer: Mobile Equipment Standard 2022 (AS/CA S042.1, S042.4, S042.5) and the Labelling Notice 2025.
Telstra certification follows the regulatory step, is recommended rather than legally required, and is paid by the manufacturer; testing takes 2 to 4 weeks on an approved module.
Telstra minimum bands: 4G B3, B7, B28; LTE-M and NB-IoT on B28; 5G n78, n7, n26; RedCap on n26. 2G and 3G must stay disabled on its network.
The Triple Zero blocking duty applies to mobile phones, not to IoT devices; voice-capable products must still meet the S042.1 emergency call clauses.

For the vocabulary (LPA, IPAd, SM-DP+, eUICC, eIM, RSP, PLMN), see the spilma glossary. For the North American counterpart, see PTCRB.

Frequently asked questions

Is the Australian RCM enough to activate a cellular IoT device on Telstra?: It is the legal floor, not the carrier step. A cellular device is customer equipment, so on top of radio and EMC it must meet the Telecommunications (Mobile Equipment Air Interface) Technical Standard 2022 (AS/CA S042.1, plus S042.4 for LTE and S042.5 for 5G) and be labelled under the Telecommunications Labelling Notice 2025. Telstra says RCM certification is the main requirement to connect to any Australian mobile network, and its IoT/M2M certification is a separate interoperability test that it strongly recommends, run after the regulatory step. The costs are set in a Device Testing and Certification Agreement and paid by the manufacturer.
Which bands does Telstra require for a new IoT device?: Telstra list of certified modules (published 30 January 2026) sets the minimum: 5G bands n78, n7 and n26; 4G bands 7, 28 and 3; LTE-M and NB-IoT on Band 28; 5G RedCap on n26. Band 28 is the 700 MHz APT plan, which a module built only for US 700 MHz bands (B12, B13, B17) does not cover. Band 5 does not appear in that minimum list.
Is 3G still available in Australia?: No. TPG Telecom (Vodafone) switched off its 3G network on 15 December 2023. Telstra closed its 3G network from 28 October 2024, and Optus began its staged shutdown the same day. Telstra now says 2G and 3G shall not be enabled when a device is on the Telstra network, though they may be enabled when roaming overseas. New devices must use 4G and 5G, with VoLTE or VoNR if they carry voice.
Will a data-only IoT device be blocked under the Triple Zero rules?: Not under the emergency call blocking duty itself. Since 28 October 2024, Part 4 of the Telecommunications (Emergency Call Service) Determination 2019 requires providers to identify mobile phones that cannot reach 000 and to stop supplying them. The Determination defines a mobile phone as a handheld device capable of voice communications and expressly excludes fixed broadband gateways, internet of things devices, personal alert devices, smartwatches and tablets. A voice-capable device sold in Australia must still meet the emergency call requirements of AS/CA S042.1.
How long does Telstra certification take?: Telstra gives 2 to 4 weeks of testing for a device built on an approved module and 6 to 8 weeks for a device on a non-certified module, subject to the defects found during testing. TPG Telecom gives about 4 to 6 weeks for its IoT Device Assurance Program when the device uses an approved IoT module and no issue appears in pre-acceptance testing. These are test durations, not the administrative steps before them.
What does Telstra publish about eSIM and eUICC?: Its certification documents do not set eUICC requirements: no GSMA SGP.32 mandate, no SAS-UP requirement and no SGP.02 retirement date appear in them. The GSMA architecture to discuss with the carrier is SGP.32 for IoT, which adds the eSIM IoT remote Manager (eIM) and the IoT Profile Assistant (IPAd in the device or IPAe in the eUICC), alongside SGP.22 for consumer devices and SGP.02 for legacy M2M.
Are PTCRB or GCF certifications recognised by Australian carriers?: None of the published Telstra or TPG documents makes PTCRB or GCF a condition or a substitute for their own testing. Telstra appears on the GCF list of Field Trial Qualified networks, which means GCF member manufacturers can run GCF field trials on its network. What the carrier will reuse from a PTCRB or GCF campaign is decided case by case with that carrier.