In recent years, with the telecom competitive landscape changing and the communications technology developing, China's telecom market has shifted from the seller's to the buyer's. Moreover, the arrival of 3G is injecting vitality to China's information services. Series of industrial policies have triggered structure optimization and reorganization, but also made the Chinese telecom companies face the changing situation more various than ever. How to “victory in changing” becomes an urgent problem of decision-makers to explore and solve. As a new organizational mode, learning organization is considered as new trends for enterprise organization and management methods and ideal management mode in Era of knowledge economy. This paper based on level response theory of complex adaptive system, discusses the impact to the change led by “organizational knowledge”, expands “structure-relationship” to the “structure-knowledge-relationship” network theory , then proposes a hypothesis about three-dimensional constitute of organizational changes and builds adaptability evolution model for learning organization under the action in complex environment. Also we give a empirical research to statistically analyze questionnaires from different telecom companies and confirm the hypothesis according to the previous analysis. Finally, the strategies to improve the adaptability of telecom operators are put forward in order to maintain continuing power for development. The conclusion of this research has some significance as reference for those who try to improve the level of the adaptability of business organizations in the various changing environment.