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SMS Sender ID Register — Compliance & Complaints Policy

Version 1.0 · Effective 1 Jul 2026

Purpose and scope

This document sets out how Real World Technology Solutions Pty Ltd (RWTS) complies with the Telecommunications (SMS Sender ID register) Industry Standard 2025 (the Standard), and how RWTS deals with, records and resolves complaints connected to the SMS Sender ID Register.

It covers two specific obligations:

  • Section 19 — implement policies and procedures to comply with all applicable obligations; and
  • Section 20 — implement policies and procedures to deal with, record and resolve complaints.

RWTS is a Carriage Service Provider operating its own carrier-grade network (AS45437), and participates in the SMS Sender ID Register. RWTS is approved under section 484F of the Telecommunications Act 1997 and appears on the ACMA’s list of approved telcos and message providers. Depending on the traffic, RWTS participates as an originating, transiting and carriage telco — including for partner telcos who send SMS through RWTS as part of their own SMS gateway and white-label offerings. This document covers RWTS’s obligations across all of those roles.

RWTS does not operate a mobile network and does not deliver SMS to recipient handsets, so it is not a terminating telco under the Standard. Inbound SMS that RWTS receives over webhooks (for example, replies routed into a customer’s helpdesk) is delivered to RWTS by an upstream mobile provider; that provider is the terminating telco, not RWTS.

This policy is reviewed at least annually, and whenever the Standard, RWTS’s systems, or RWTS’s participation in the Register materially change.

Part A — Compliance policy (Section 19)

A.1 Roles and responsibilities

The Managing Director holds overall accountability for RWTS’s compliance with the Standard. Day-to-day responsibility sits with the nominated SMS Sender ID Register compliance owner, supported by the network engineering and support teams who run the SMS platform and the interconnects.

The compliance owner maintains this policy, keeps RWTS’s entry on the ACMA approved list current, lodges the quarterly reports, responds to ACMA information requests, and makes sure the controls below are in place and working.

A.2 Participation and approval

RWTS participates in the Register only in the roles for which it holds approval under section 484F of the Telecommunications Act 1997. It does not send, transit or terminate sender ID messages in a way that needs an approval it doesn’t hold. Before taking on a new mode of participation, RWTS confirms it holds the relevant approval and updates this policy.

A.3 Registering and verifying sender IDs (originating role)

RWTS registers alphanumeric sender IDs only for entities with a valid Australian Business Number (ABN). It does not register sender IDs on behalf of non-ABN entities, and it is not a Certified telco under section 7 of the SMS Sender ID Register (Application, Access and Administration) Determination 2025. If a customer or partner can’t be verified as an ABN entity, RWTS does not register a sender ID for them.

Before submitting each sender ID registration application to the ACMA for an ABN entity, RWTS completes a valid use-case verification under Section 11 of the Standard.

Before enabling any account to send sender ID messages, RWTS confirms all of the following under Section 16:

  • the sender ID is registered on the SMS Sender ID Register;
  • the person asking for the account to be enabled is authorised by the entity the sender ID is registered to; and
  • RWTS is authorised, via the Register, to send messages for that sender ID.

If any of these can’t be confirmed, the account is not enabled to send that sender ID.

A.4 Disruption of non-conforming messages

Where a sender ID message doesn’t meet the confirmation requirements in A.3 — in particular, where the sender ID isn’t registered — RWTS disrupts the message by over-stamping it with a new sender ID of “Unverified”, under Section 16.

A.5 Transiting role

When RWTS transits sender ID messages between other telcos, it transits a message only where it has confirmed that both the telco sending the message and the telco the message is being transited to are participating in the Register, under Section 17. RWTS checks participation against the ACMA’s published list of approved telcos and message providers.

RWTS applies the exemptions in Section 17(3) and (4): where a message is bound for a mobile number using an international mobile roaming service, and where a message is received from an international telecommunications service provider that RWTS has over-stamped with “Unverified”.

A.6 Partner arrangements

Where another telco sends SMS through RWTS as part of that telco’s gateway or white-label offering, or where RWTS relies on another telco to fulfil obligations (or another telco relies on RWTS), the split of obligations under the Standard is recorded in a written contractual arrangement, consistent with Section 13. Each arrangement makes clear which party carries the originating obligations for the relevant traffic.

A.7 Customer information and notifications (originating role)

RWTS communicates information about the SMS Sender ID Register as required by Sections 9 and 10 and Schedule 1 of the Standard:

  • the information is published on the Real World website;
  • it is communicated in writing to a customer when they request a new sender ID; and
  • existing customers using sender IDs are notified in writing.

RWTS’s public-facing communications do not inaccurately describe the matters set out in Sections 14 and 15.

A.8 Scam identification and notification

When RWTS identifies a scam communication, it notifies the ACMA in writing within two business days, under Section 21. Where RWTS is acting in a transiting role, it also notifies the telco that sent the message within the same period.

A.9 Security and privacy

RWTS takes all reasonable steps to keep its IT systems and processes secure, in particular the systems used for sending sender ID messages and for interacting with the Register, under Part 25 of the Standard. RWTS notifies the ACMA in writing as soon as practicable after becoming aware of a breach or suspected breach of security.

RWTS is subject to the Privacy Act 1988 and handles personal information in line with the Real World Group privacy policy.

A.10 Records, reporting and information requests

RWTS keeps records demonstrating compliance with the Standard for a minimum of two years, maintains the privacy and integrity of those records, and securely destroys them when they’re no longer required, under Part 6.

RWTS lodges its SMS Sender ID Register quarterly report with the ACMA within 20 business days after the end of each quarter, under Section 22. This report is separate from RWTS’s other carrier reporting. Where there is no reportable sender ID activity for a quarter, RWTS lodges a nil return.

RWTS makes compliance records available to the ACMA within five business days of a written request, under Sections 23 and 24.

A.11 Testing and readiness

RWTS has tested its systems and processes to confirm they perform and meet the compliance obligations under the Standard from 1 July 2026. Material changes to the SMS platform or the Register interface are tested for continued compliance before they go live.

Part B — Complaints policy (Section 20)

This Part sets out how RWTS deals with, records and resolves complaints connected to the SMS Sender ID Register, as required by Section 20.

B.1 What this covers

This policy covers complaints about RWTS’s handling of sender ID messages and sender ID registrations under the Standard — for example, a sender ID that was disrupted or over-stamped as “Unverified”, a delay or problem registering a sender ID, or a message a complainant believes should or should not have been carried.

B.2 How to make a complaint

A complaint can be made:

  • by phone on 1300 798 718;
  • by email to [email protected]; or
  • through the Real World helpdesk.

A complaint doesn’t need to be in any particular form. RWTS accepts complaints from customers, partner telcos, message recipients and the ACMA.

B.3 How RWTS handles a complaint

When a complaint comes in, RWTS:

  • records it in the support and ticketing system, with the date received, the complainant, and the substance of the complaint;
  • acknowledges the complaint to the complainant;
  • assigns it to the right person — sender ID and Register matters are escalated to the SMS Sender ID Register compliance owner;
  • investigates, including reviewing the relevant message and registration records; and
  • resolves the complaint and tells the complainant the outcome.

Where a complaint reveals a compliance issue, the compliance owner makes sure it’s corrected and considers whether any change to RWTS’s systems or procedures is needed to stop it happening again.

B.4 Records

RWTS records each complaint and its resolution, and keeps those records for a minimum of two years, consistent with Part 6. Complaint records are available to the ACMA on request within the timeframes in A.10.

B.5 Privacy

Personal information collected in handling a complaint is managed under the Privacy Act 1988 and the Real World Group privacy policy. It is not disclosed to a third party except as required to manage the complaint, with the person’s express consent, or where required or authorised by Australian law or a court order.

B.6 Escalation

If a complainant isn’t satisfied with the outcome, they can ask for the matter to be escalated to the compliance owner or the Managing Director. Complaints about RWTS’s compliance with the Standard can also be raised with the ACMA at [email protected].

Last updated: June 18, 2026