Gazette Tracker
Gazette Tracker
Register
Telecom Regulatory Authority of India

In exercise of the powers conferred by section 36, read with sub clauses ii, iii and iv of clause b of sub section 1 of section 11, of the Telecom Regulatory Authority of India Act,

Issue Date: 15 September 2023 Published: 16 September 2023
Gazette ID: CG-DL-E-16092023-248799 Download PDF Official source ↗
Back to Feed
Cite this gazette 

                    
                

            

        


        
        
        

            

                
                    
                    
                    
                
                Core Purpose
            

            
Notification of the Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Fifth Amendment) Regulations, 2023, amending the 2017 principal regulations to add a new Schedule X prescribing audit scope, scheduling, and Digital Rights Management/Subscriber Management System requirements.

        

        

        
        
        

            

                
                    
                    
                    
                    
                
                Detailed Summary
            

            
This notification, issued by the Telecom Regulatory Authority of India (TRAI) on 14th September 2023 under file number C-1/2/(1)/2021-B AND CS(2), promulgates the 'Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Fifth Amendment) Regulations, 2023' (4 of 2023), made in exercise of powers under Section 36 read with sub-clauses (ii), (iii) and (iv) of clause (b) of sub-section (1) of Section 11 of the Telecom Regulatory Authority of India Act, 1997 (24 of 1997), read with Central Government notification No. 39 (S.O.44(E) and S.O.45(E) dated 9th January 2004). The Regulations amend the Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) Regulations, 2017 (1 of 2017) ('the principal regulations'), apply throughout India, and take effect from publication, with a three-month grace period for existing systems. Substantive changes amend Regulation 10(6) and (7) and Regulation 15(2)/(2)-proviso, and item 17 and the declaration in Schedule II of the principal regulations, to reference a newly inserted 'Schedule X' as an alternative to 'Schedule III'. The new Schedule X, inserted after Schedule IX, prescribes the scope and scheduling of the annual Audit (including the Subscription Audit) that a distributor must cause to be conducted, requiring at least six months and no more than eighteen months between audits of consecutive calendar years, and sets out detailed Digital Rights Management (DRM) requirements for Subscriber Management Systems (SMS) used for IPTV services -- including permissible DRM/SMS data-mismatch thresholds tiered by subscriber base (0.20% up to 100,000 subscribers, 0.04% up to 1,000,000 subscribers, 0.01% above 10,000,000 subscribers) with monthly reconciliation and three-year record retention, password policy or MAC ID pairing requirements, 99.99% uptime after-sales support located in India, real-time SMS-DRM synchronisation, 24-hour activation/deactivation capability, three-year log retention, mandatory subscriber and product data fields, extensive reporting capabilities, Network Capacity Fee (NCF) policy support, GST-inclusive billing, tamper-proof logging, database integrity rules, firewall access, and one-time-password (OTP) based subscriber authentication via registered mobile number.

        

        

        
        

            

                
                    
                    
                    
                    
                    
                
                Full Text
            

            
            

                
EXTRAORDINARY
PART III—Section 4
PUBLISHED BY AUTHORITY
(2023 का 4)
No. 642] NEW DELHI , FRIDAY , SEPTEMBER  15, 2023/ BHADRA  24, 1945
CG-DL-E-16092023-248799

TELECOM REGULATORY AUTHORITY OF INDIA
NOTIFICATION
New Delhi, the 14th September, 2023
THE TELECOMMUNICATION (BROADCASTING AND CABLE) SERVICES
INTERCONNECTION (ADDRESSABLE SYSTEMS) (FIFTH AMENDMENT) RE GULATIONS, 2023
(4 of 2023)
F. No. C -1/2/(1)/2021 -B AND CS(2)  — In exercise of the powers conferred by section 36, read with sub -
clauses (ii), (iii) and (iv) of clause (b) of sub -section (1) of section 11, of the Telecom Regulatory Authority of India
Act, 1997 (24 of 1997), read with notification of the Central Government, in the Ministry of Communication and
Information Technology (Department of Telecommunications), No. 39, —
(a) issued, in exercise of the powers conferred upon the Central Government unde r clause (d) of sub -section
(1) of section 11 and proviso to clause (k) of sub -section (1) of section 2 of the said Act, and

(b) published under notification No. S.O.44 (E) and 45 (E) dated the 9th January, 2004 in the Gazette of
India, Extraordinary, Par t II, Section 3, —
the Telecom Regulatory Authority of India hereby makes the following regulations further to amend the
Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) Regulations, 2017 (1
of 2017), namely: -
1. Short  title, extent, and commencement. —
(1) These regulations may be called the Telecommunication (Broadcasting and Cable) Services
Interconnection (Addressable Systems) (Fifth Amendment) Regulations, 2023 (4 of 2023).
(2)    These regulations shall apply throu ghout the territory of India.
(3) These regulations shall come into force from the date of their publication in the Official Gazette.
Provided that for the existing systems, the provisions of these regulations shall apply after three months
from the date o f their coming into force.
2. In regulation 10 of the Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable
Systems) Regulations, 2017 (hereinafter referred to as the ―principal regulations‖), —
(a) in sub -regulation (6), after th e words ―Schedule III‖, the words ―or the Schedule X or both, as the
case may be‖ shall be inserted;
(b) in sub -regulation (7), for the words ―Schedule III‖, the words ―Schedule III or the Schedule X or
both, as the case may be‖ shall be substituted;
(c) in proviso to sub -regulation (7), after the words ―Schedule III‖, the words ―or the Schedule X or both,
as the case may be‖ shall be inserted.
3. In regulation 15 of the principal regulations, —
(a) in sub -regulation (2), for the words ―Schedule III‖, th e words ―Schedule III or the Schedule X or
both, as the case may be‖ shall be substituted;
(b) in third proviso to sub -regulation (2), after the words ―Schedule III‖, the words ―or the Schedule X or
both, as the case may be‖ shall be inserted.
4. In Schedu le II of the principal regulations, —
(a) in item 17, for the words ―Schedule III‖, the words ―Schedule III or the Schedule X or both, as the
case may be,‖ shall be substituted;
(b) in declaration, for the words ―Schedule III‖, the words ―Schedule III or th e Schedule X or both, as the
case may be,‖ shall be substituted.
5. After Schedule IX to the principal regulations, the following schedule shall be inserted, namely: -
“Schedule X
(Refer sub -regulation (6) of the regulation 10, sub -regulation (7) of the regul ation 10 and sub -regulation (2) of the
regulation 15)
Scope and Scheduling of Audit
(A) Scope: The annual Audit caused by distributor shall include the Audit to validate  compliance with this Schedule
and the Subscription Audit, as provided for in these re gulations.
(B)   Scheduling: The annual Audit as caused by distributor under regulation 15(1) shall be scheduled in such a
manner that there is a gap of at -least six months between the audits of two consecutive calendar years. Further,
there should not be a gap of more than 18 months between audits of two consecutive calendar years.
Digital Rights Management (DRM) System Requirements
The term DRM, herein, refers to the management of the encryption systems for, inter -alia, providing the functionality
of CAS for the Internet Protocol Television (IPTV) service provider under these regulations.
(C) DRM Requirements in so far as they relate to subscriber management systems (SMS) for IPTV services:

Table 1
Sl. No.  Proposed DRM requirements for SMS
1. There shall  not be any data mismatch between DRM and SMS.  Maximum mismatch based on
subscription base may be allowed as mentioned below:
(4) Must be less than 0.20% for subscriber base up to 100000 subs (0 to 200 for subscriber base of
up to 100000)
(5) Must be less than 0. 04% for subscriber base up to 1000000 subscribers (0 to 400 for subscriber
base of up to 1000000)
(6) Must be less than 0.01% for subscriber base above 10000000 subscribers (0 to 1000 for
subscriber base of up to 10000000)
The data between both the systems sha ll be reconciled on a monthly basis. The reconciliation report shall
be stored along with the system data for a minimum of three (3) years or  at least three audit cycles, or as
per Schedule III whichever is later.
2. Password Policy Creation for Users : SM S shall have a defined password policy, with minimum length
criteria and composition (upper and lower -case characters, numeric, alphabets or special characters),
forced password changes or any other appropriate mechanisms or combinations thereof or alterna tively
user account has to be locked/paired to the Mac Id of the set top box (STB) /unique consumer subscription
or the customer pr emises equipment (CPE)/device.
3. After -Sales Service Support : The required software and hardware support should be availab le to the
distributor of the television channels‘ installations from the SMS vendor‘s support teams located in India.
The support should be such as to ensure the SMS system with 99.99% uptime and availability. The
systems should have sufficient provisions for backup systems to ensure quality of service and uptime
4. All activation and deactivation of STBs/unique consumer subscription shall be done in such a way that
SMS and DRM are always integrated and synchronised on real time basis.
5. Necessary and s ufficient methods shall be put in place so that each activation and deactivation of
STBs/unique consumer subscription is reflected in the reports generated from the SMS integrated with the
DRM and vice versa
6. DRM and SMS should be able to activate or de activate services and/or STBs/unique consumer
subscription of the subscriber base of the distributor within 24 hours.
7. The SMS shall be independently capable of generating, recording, and maintaining logs, for the period of
at least immediately precedin g three (3) consecutive years, corresponding to each command executed in
the SMS including but not limited to activation and deactivation commands.
8. The SMS should be computerized and capable of recording all logs including information and data
concerni ng the subscribers such as:
(a)     Unique customer identification (ID)
(b)     Subscription contract number
(c)     Name of the subscriber
(d)     Billing address
(e)     Installation address
(f)      Landline telephone number
(g)     Mobile telephone num ber
(h)     E-mail address
(i)      Channels, bouquets and services subscribed
(j)      Unique STB number/unique consumer subscription ID attached to a specific unique MAC ID.
(k)     Unique VC number or MAC ID.
9. The SMS should be capable of:
(a) Viewing an d printing of historical data in terms of the activations and the deactivations of
STBs/unique consumer subscription.
(b) Locating each and every STB/unique consumer subscription and VC/MAC ID installed at city
and state level.
(c) Generating historical data of ch anges in the subscriptions for each subscriber and the
corresponding source of requests made by the subscriber.
10. The SMS should be capable of generating reports, at any desired time including about:
(a) The total number of registered subscribers.

(b) The tota l number of active subscribers.
(c) The total number of temporary suspended subscribers.
(d) The total number of deactivated subscribers.
(e) List of blacklisted STBs/unique consumer subscription in the system.
(f) Channel and bouquet wise monthly subscription report in t he prescribed format.
(g) The names of the channels forming part of each bouquet.
(h) The total number of active subscribers subscribing to a particular channel or bouquet at a given
time.
(i) The name of a -la carte channel and bouquet subscribed by a subscriber.
(j) The ageing report for subscription of a particular channel or bouquet.
11. The distributor shall ensure that the SMS vendor has the technical capability in India to maintain the
systems on 24×7 basis throughout the year.
12. DPO shall declare the details of the DRM and the SMS deployed for distribution of channels. In case of
deployment of any additional DRM/SMS, the same shall be notified prior to commissioning of the
system, to the broadcasters by the distributor.
13. If there is active infrastructure shar ing (as  and when permitted by MIB)  then, DPO shall declare the
sharing of the DRM and the SMS deployed for distribution of channels. In case of deployment of any
additional DRM/SMS, the same should be notified to the broadcasters by the distributor.
14. SMS shall have a provision to generate synchronization report, with date and time, with the minimum
fields as listed below:
(a) STB/unique consumer subscription Number (or in case of card -less system, chip ID or MAC ID
number of the STB)
(b) Product Code pertainin g to à -la-carte channels and bouquets available on the platform
(c) Start Date of entitlement
(d) End Date of entitlement
(e) Status of STB/unique consumer subscription (active/Inactive)
15 The file output of DRM shall be processed by SMS system to compare and gen erate a 100% match or
mismatch error report.
16. Channel/Bouquet management : SMS shall, in synchronisation with DRM on real time basis, support the
following essential requirements:
(a) Create and manage relevant product ID for all channels and bouquets alon g with the relevant
details such as name, tariff, broadcaster, or DPO bouquet, etc.
(b) Manage changes in the channel/bouquet, as may be required, from time to time.
(c) Link the Products IDs for à -la-carte channels and bouquets (Single and Bulk) created in DRM
with the product information being managed in SMS, for smooth working of SMS and DRM
integration.
(d) Management of historical Data of Product name, i.e., Broadcasters (name), maximum retail price
(MRP), distributor retail price (DRP).
17 Network Capacity F ee (NCF) Policy Creation : SMS shall support all NCF related requirements
mandated b y the applicable tariff order.
18. Bill/Invoice Generation : SMS shall be capable of generating proper subscriber bill/invoice with explicit
details of NCF charges, pay cha nnels charges (with clear itemized details of à -la-carte channel cost and
bouquet costs), rental charges for STB/unique consumer subscription (if any), other applicable charges,
including  Goods and Services Tax (GST).
19. Management of Logs :
(a) SMS shall have the facility to provide user detail logs with the ID of users on each login event.
(b) SMS shall have the provision of generating the user activity log report to enable tracking users‘
work history. It shall not be allowed to delete the records from the  log.
(c) All logs shall be stamped with date and time and the system shall not allow altering or modifying
any logs.

(d) The logs shall be maintained for a period as specified in Schedule III or at least three audit
cycles, whichever is later.
(e) Channel subscript ion report: SMS shall be able to provide broadcaster wise total counts of
monthly subscribers of channels including both à la carte and bouquet subscriptions as per format
that may be prescribed by TRAI.
(f) DRM and SMS should be running on separate and indep endent servers.
20. SMS Database and tables :
(a) There shall not be any active unique subscriber outside the database tables declared by the
Vendor
(b) SMS shall not provide an option to split SMS database or for creation of more than one instance.
(c) SMS shall  have the provision to enable or disable channel (à -la-carte channel or bouquet of
channels) selection by subscribers either through website or an application through interface
provided by the distributor platform operator.
(d) SMS shall be capable of capturi ng the following information required for audit or otherwise:
i. Bouquet à la carte status change history
ii. Bouquet composition change history
iii. Change in status of connection (primary to secondary and vice versa)
21. SMS shall be accessed through a Firewall
22. STB/unique consumer subscription and MAC ID shall be paired from the SMS to ensure security of
channel (applicable for DRM with pairing facility).
23. The SMS shall be capable of individually addressing subscribers, for the purpose of generating the
reports, on channel by channel and STB/unique consumer subscription by STB/unique consumer
subscription basis.
24. SMS should have a facility to carry out monthly reconciliations of channels/a -la-carte and bouquet (with
their respective ID created in SM S with DRM) and the variance report should be available from the DRM
and SMS logs and made available during audits.
25. SMS should have a provision of generating the following reports pertaining to STB/unique consumer
subscription/MAC ID.:
(a) White list of STB/unique consumer subscription /MAC ID along with active/inactive status
(b) Faulty STB/unique consumer subscription/MAC ID – repairable and beyond repairable
(c) Warehouse fresh stock
(d) In stock at local cable operator (LCO) end
(e) Blacklist
(f) Deployed with activ ation status
(g) Testing/demonstration STB/unique consumer subscription /MAC ID with location
26. Audit -related requirements :
SMS should have the capability to capture below -mentioned information that may be required for audit
and otherwise:
(a) Subscriber r elated:
(i) Subscriber contact details change history
(ii) Connection count history
(iii) Transition of connection between Disconnected/Active/Temporary Disconnected
(iv) Subscription change history
(b) Product (Bouquet/à -la-carte channel) related:
(i) Broadcaster à -la-carte re lation
(ii) Bouquet name change history
(iii) À la carte name change history

(iv) Bouquet/à -la-carte channel rate change history
(c) STB/unique consumer subscription related:
(i) Change in location history
(ii) Change in status (Active/Damaged/Repaired/Replaced)
27. User Authe ntication : SMS should have the capability to authenticate its subscribers through registered
mobile number (RMN) through one -time password (OTP) system
28. SMS should have the provision to support the following additional requirements:
(a) List of à -la-carte channels and bouquets, digital headend (DHE): Provision to support/ Sub -
Headend -wise list of à -la-carte channels and bouquets, in sync with the list available in DRM.
(b) Product (à -la-carte channels and bouquets) -wise Renewal and Reversal setting for the Sub scriber
Account: Provision to allow renewal of a product to a subscriber after the expiry date of a
product, and provision to auto -calculate and refund the amount to a subscriber if he discontinues
a product midterm. These requirements may be configurable on selective products, as required by
the DPOs as per their business plans.
(c) Product (à -la-carte channels and bouquets) -wise Reversal setting for LCO Account: Provision to
calculate and refund the amount due to LCO, if he or the subscriber discontinues a p roduct
midterm.   Product (à -la-carte channels and bouquets) Tenure -wise LCO and Subscriber Discount
Scheme/Free Days Scheme: Provision to create Discount Scheme and Free -day scheme for LCO
and Subscriber, based on the duration (Tenure) of the product subsc ription.
(d) Calendar/Activity Scheduling: Provision to auto -schedule activities like STB/unique consumer
subscription activation/deactivation, à -la-carte channels and bouquets addition/removal,
channel/bouquet composition modification, etc.
(e) Bulk Channel/B ouquet Management: Provision to perform bulk activity of à -la-carte channels
and bouquets addition and removal on all or a designated group of STBs/unique consumer
subscription.
(f) Token -number -based reports: Provision to download multiple generated reports w ith the help of
token number, such as audit reports with different intervals.
(g) Third -Party Integration: Provision to support integration with relevant third -party systems, such
as, payment gateway integrations, interactive voice response (IVR) Integration s, SMS Gateway
Integrations, etc.
(h) Bill payment and reconciliation feature: Provision for bill payment and reconciliation (in case a
DPO is running service in post -paid mode).
(i) Generation of Reports: Provision to generate the following reports for operati onal purpose:
(i) All, selective and single boxes‘ current status with their first -time activation date.
(ii) Total number of à -la-carte channels and bouquets and STB/unique consumer subscription
expiring detail till given future date on the dashboard, according to the permission.
(iii) Today‘s fresh activation count, de -activation count, re -activation count, à -la-carte
channels and bouquets addition/ removal count on dashboard, according to the
permission.
(iv) Total active and inactive subscriber‘s details with multiple criteria (network -wise, à la -
carte channels and bouquets -wise, state -city wise and broadcaster -wise).
29. It shall be mandatory for SMS to have backup servers and logs of all activities carried out in
main server shall be concurrently copied into the bac kup servers, in an automated manner
without any manual intervention.
Provided that a log of all such instances shall be maintained along with date and time
stamp, where the backup server has been used as the main server:
Provided further that the main an d backup server shall always be in sync with regard all data,
such as subscription data, STB/unique consumer subscription UA/MAC ID details, entitlement
level information, etc.

(D) DRM Requirements for conditional access by subscribers and encryption fo r IPTV services
Table 2
Sl. No.  Proposed DRM Requirements for conditional access by subscribers and encryption
1. DPO shall ensure that the current version of the DRM in use do not have any history of hacking. A
written declaration from the DRM vendor sha ll be required to be furnished on an annual basis as
compliance of this requirement.
2. DRM shall ensure all logs are un -editable, stamped with date and time of all transactions (all
activations, deactivation, channel authorization/assignment and un -autho rization / de -assignments and
change in MAC ID/STB/unique consumer subscription). The DRM shall not allow altering or
modification of any logs. There shall be no facility for the distributor/users to purge logs.
3. DRM deployed do not have facility to act ivate and deactivate a Set Top Box (STB) /unique consumer
subscription directly from the Graphical User Interface (GUI) terminal of DRM. All activation and
deactivation of STBs/unique consumer subscription shall be done with the commands of the SMS
(provid ed that such feature may be available only for specific testing. The command or access for such
feature may be available with the highest system administration password. In all such cases a separate
log file of such commands has to be maintained) integrate d with DRM. The DRM shall be integrated
with the SMS in a manner that ensures security of the channel.
4. The SMS and the DRM should be integrated in such manner that activation and deactivation of
STB/unique consumer subscription happen simultaneously in  both the systems.
Explanation : Necessary and sufficient methods shall be put in place so that each activation and
deactivation of STBs/unique consumer subscriptions is reflected in the reports generated from the
DRM.
5. DRM deployed should be able to su pport two -way networks only.
6. The DRM deployed should be able to support both carded as well as card -less STBs/unique consumer
subscription for any provisioning.
7. The DRM deployed should be able to generate, record, maintain independent reports and logs for
verification purpose during audits corresponding to each command executed in the DRM issued by the
SMS integrated with the DRM for last three (3) years minimum. The reports must have date and time
stamp. Proposed reports should include:
(a) Unique ac tive STB/unique consumer subscription count as well as MAC ID wise on any
desirable date
(b) Unique bouquet/channel active for a specific STB/unique consumer subscription on any
desirable date
(c) MAC ID/User ID wise activation -deactivation report for service requ ests
(d) Any alteration in bouquet and/or channels configured in DRM
(e) Blacklist STB/unique consumer subscription report (desirable not mandatory feature)
(f) Product code pertaining to channels/ bouquets available on the platform
(g) Channel/bouquet authorization/ass ignment to STB/unique consumer subscription along with
start date and end date of entitlement
(h) STB/unique consumer subscription -VC pairing / de -pairing or User id - Mac-id Pairing / de -
pairing (if applicable) in SMS/DRM
(i) STB/unique consumer subscription acti vation / de -activation
(j) Channels assignment to STB/unique consumer subscription
(k) Report of the activations or the deactivations of a particular channel for a given period
(l) The total number of registered subscribers
(m) The total number of active subscribers
(n) The t otal number of temporary suspended subscribers
(o) The total number of deactivated subscribers

(p) List of blacklisted STBs/unique consumer subscription in the DRM (desirable not mandatory
feature)
(q) Channel and bouquet wise monthly subscription report in the prescr ibed format.
(r) The names of the channels forming part of each bouquet
(s) The total number of active subscribers subscribing to a particular channel or bouquet at a
given time
(t) The name of a -la carte channel and bouquet subscribed by a subscriber
(u) The ageing repor t for subscription of a particular channel or bouquet
8. DRM deployed should be able to tag and blacklist the STB/unique consumer subscription in case of
any piracy.
9. DRM deployed should have the technical capability in India to maintain the systems on  24x7 basis
throughout the year.
10. The DRM and SMS should be integrated in such manner that upon deactivation of any subscriber from
the SMS, all program/services shall be denied to that subscriber.
11. The DRM should be capable of generating, recordi ng and preserving unedited data / logs for at least
three consecutive years for each command executed through the DRM, including logs of each
command of the SMS integrated with the DRM.
12. DRM deployed should be capable to support both software base as well as hardware base security.
13. DRM shall be capable of adding/modifying channels/bouquets as may be required on real time basis in
line with the activity performed in SMS.
14. DRM should be so configured for specific type of STB/unique consumer su bscription, that are
procured and configured by the DPO. The DRM should not enable working/operation of any other
type/brand/make of STB/unique consumer subscription, in the network.
15. When infrastructure sharing (as and when permitted by MIB) is avail able, in such cases DRM shall be
capable to support multiple DPOs.
16. DRM should support content protection.
17. DRM should support key rotation, i.e., periodic changing of security keys
18. In case DPO has deployed hybrid STBs (hybrid STB for the pur pose of this regulation means a STB
that uses multiple methods of receiving transmission signals with video and audio content, however in
a single instance such STB provides only one type of service) , DRM shall ensure that the over -the-top
(OTT) App and an y browser does not get access to the linear television channels offered by the DPO
from its own system, and similarly, DRM for IPTV service should not get access to channels delivered
through OTT platform. Provided that, all the mandatory requirements for DRM shall be complied by
hybrid STBs.
19. There shall not be any active unique subscriber outside the database tables. Further, there shall not be
an option to split DRM database for creation of more than one instance by a DPO or a vendor.
20. It must support the following options with reference to uploading of unique access (UA)/MAC ID
details in DRM database:
(a) A secure un -editable file of MAC ID details, as purchased by the distributor, to be uploaded
by the DRM vendor on the DRM server directly,
(b) If it is uploaded in any other form, UA/MAC ID in DRM database shall be captured in logs,
(c) Further, DRM shall support an automated, application programming interface (API) -based
mechanism to populate such UA/MAC ID details in the SMS, without any manual
intervention.
21. It shall be mandatory to have backup servers and logs of all activities carried out in main server shall be
concurrently copied into the backup servers:
Provided that a log of all such instances shall be maintained along with date and time s tamp, where the
backup server has been used as the main server:

Provided further that the main and backup server shall always be in sync with regard all data, such as
subscription data, STB/unique consumer subscription UA/MAC ID details, entitlement leve l
information, etc
22. DRM and SMS shall ensure that the access to database is available to authorized users only, and in
―read only‖ mode only. Further, the database audit trail  shall be permanently enabled.
Explanation : Database here refers to the data base where data and log of all activities related to
STB/unique consumer subscription activation, deactivation, subscription data, STB/unique consumer
subscription UA/MAC ID details, entitlement level information, etc., is being stored.
23. Provision of  à-la-carte channels or bouquet :
(a) DRM (and SMS) shall be able to handle all the channels, made available on a platform, in à la
carte mode.
(b) DRM (and SMS) shall have the capability to handle such number of broadcaster/DPO
bouquets, as required by the DPO.
24. DRM and SMS applications, along with their respective databases, shall be stored in such a way that
they can be separately identified.
25. DRM shall have a provision to export the database/report for reconciliation with the SMS database.
Further,  there shall be a provision of reconciliation through secure APIs/secure scripts.
26. There shall be unique license key required for viewing, the encryption period for a specific key should
be configurable to change at periodic interval in DRM deployed by DPO.
27. For every change in channels, fresh license keys should be issued by the DRM. License keys issued by
DRM should be secure and encrypted. DRM must ensure that the authorization keys are not received
by the STB /unique consumer subscription  from any other source other than the one specified by the
IPTV system.
28. DRM servers should comply with extant Rules and Regulations including relevant clause under extant
provisions (if any) relating to data localisation, data security and privacy. It shoul d not be allowed to
connect main DRM server to some other location (India or other country) with some proxy or another
server to integrate with SMS and DPO system.
29. IPTV service delivery may conform to multicast and/or unicast mode. The system configur ation should
ensure that every television channel is available to every customer on selection to view, irrespective of
the mode of delivery or the number of viewers seeking such channel at any point of time. STBs/unique
consumer subscription with facilitie s for recording programs shall have a copy protection system (i.e., a
feature which prevents reproduction of content and/or unauthorized copying and distribution of
content) and such recorded content should not be transferrable to any other device or deliv ered to any
other network in any manner whatsoever.
30. IPTV system should not be allowed to deliver linear content to any other device except STB/unique
consumer subscription which has been whitelisted in DRM.
31. The DRM should have following features :
(a) It should restrict user to editing.
(b) It should restrict user from sharing or forwarding or mirroring the content from the
STB/unique consumer subscription.
(c) It should disallow user to take screen shots or screen grabs or screen -recording, if technically
feasible.
(d) It should lock access to authorized STBs/unique consumer subscriptions only.
(e) It should have Geo blocking feature.
(f) It should be able to set expiry date to recorded content at STB/unique consumer subscription
end based on various policies.
32. The DRM should have the capability of being upgraded over -the-air (OTA) so that the connected
STBs/unique consumer subscription always have the most upgraded version of the DRM.
33. The DPO shall ensure that the DRM is up to date by installing necessary patch es, error corrections,
additions, version releases, etc. so as to ensure protection of channels and content at all times

34. No such functionality should be added to or removed from the DRM which compromises security of
channels. DPO shall be responsible for encryption of channels‘ signals before their delivery through its
IPTV platform using DRM hybrid STBs/unique consumer subscription. All costs / expenses (by
whatever name called) that are required to be incurred or become payable for such upgradation a nd for
delivery/distribution of multi channel television programmes to subscribers shall be borne solely by
such DPO. The DPO shall employ all reasonable security systems and procedures to prevent any loss,
theft, piracy, un -authorized use, reception or co pying of channels or any part thereof and shall notify
broadcasters as soon as practicable after it becomes aware that such an event has occurred
35. The DRM should not in any way interfere with / invalidate fingerprinting.
36. DPO shall promptly, and at  it sole cost and expense, correct any issues with the DRM (such as bugs,
defects, omissions or the like) that prevents subscribers from accessing the DRM hybrid STBs/unique
consumer subscription or channels through the DRM hybrid STBs/unique consumer subs cription.
37. DPO shall provide broadcasters with video and audio codecs supported by the DRM hybrid
STBs/unique consumer subscription. The DPO shall ensure that no such changes/modifications are
made to such codecs parameters that will require broadcaste rs to incur any expense for delivery of
channels / content that are free from viewer discernible problems (including, without limitation, video
with no audio, audio with no video or significant signal distortion
38. DRM should ensure that the hybrid STBs/ unique consumer subscription are verifiably located within
India by reference to internet protocol address and service address. DRM must ensure and lock the
viewership to single device by single STB/unique consumer subscription or any device by ensuring
MAC ID based authentication. The DRM must use industry -standard means (including IP -address
look-up technology with screening and blocking of proxies (including anonymizing and spoofed
proxies)) to prevent delivery of channels to IP addresses outside of Indi a or to proxies.
39. DRM should ensure that television channels are accessible on STBs/unique consumer subscription of
only such subscribers who are then -current, valid subscribers of the DPO, and such confirmation must
take place prior to the DRM deliver ing (or authorizing the delivery of) television channel to the
STBs/unique consumer subscription of such subscribers.
40. Upon deactivation of any subscriber from the SMS, the DRM shall restrict delivery of all
programme/services to that subscriber.
41. The DRM should not have any feature to insert any content (including advertisement, banner on
portion of screen, etc) by itself. However, ticker messages for consumer information as regards their
services from DPO shall be permitted.
42. The DRM should no t mask/remove any copyright, trademark or any other proprietary information on
the channels at the time of their delivery.
The service providers shall ensure that they seek provisioning of after sales services and support through a local entity
so as to  inter -alia provide quick resolution to any technical and piracy related issues, from DRM equipment supplier,
while procuring DRM equipment.
(E) DRM Requirements in so far as they relate to fingerprinting for IPTV services
Table 3
Sl. No  Fingerprinting  requirements under DRM
1. The DPO shall ensure that it has systems, processes and controls in place to run fingerprinting  at
regular intervals
2. The STB/unique consumer subscription should support both visible and covert types of finger
printing.
3. The fingerprinting should not get invalidated by use of any device or software.
4. The fingerprinting should not be removable by pressing any key on the remote of STB/unique
consumer subscription.
5. The finger printing should be on the topmost layer of the video.
6. The finger printing should be such that it can identify the unique STB/unique consumer

subscription number or the unique VC number or the MAC ID.
7. The finger printing should appear on the screens in all scenarios, such as menu, Electronic
Programme Guide (EPG), settings, blank screen, and games etc.
8. The location, font color and background color of fingerprint should be changeable from head end
and should be random on the viewing device.
9. The finger printing should be able to give the nu mbers of characters as to identify the unique
STB/unique consumer subscription and/or the MAC ID.
10. The finger printing should be possible on global as well as on the individual STB /unique consumer
subscription  basis.
11. The overt fingerprinting/water marking should be displayed by the DPO without any alteration with
regard to the time, location, duration and frequency.
12. The DRM deployed should be able to generate fingerprinting/watermarking both global
fingerprinting as well as targeted channel fin gerprinting/watermarking.
13. The DRM shall support and enable forensic watermarking at STB/unique consumer subscription
level.
14. The DRM shall have the capability to run fingerprinting with at least one fingerprinting every ten
(10) minutes on a 24x 7x365 basis.  DRM should have a feature to publish report of fingerprinting
schedule for defined interval. The DPO shall make such report available to broadcaster on request.
(F) DRM Requirements in so far as they relate to STBs /unique consumer subscri ption
Table 4
Sl. No.      STB /unique consumer subscription  Requirements for DRM for IPTV services
1. All STBs/unique consumer subscription  should have a DRM content protection.
2. The STB/unique consumer subscription  deployed should be capable to  support content decryption,
decoding and DRM license evaluation.
3. The STB/unique consumer subscription  should be capable of displaying fingerprinting inserted from
Headend through DRM/SMS. The STB/unique consumer subscription  should support both targeted
channel fingerprinting as well as all global fingerprinting.
4. The STB/unique consumer subscription  should be individually addressable from the Head -end.
5. The STB/unique consumer subscription  should be able to receive messages from the Head -end.
6. The messaging character length should be minimal of upto120 characters.
7. There should be provision for global messaging, group messaging and the individual STB /unique
consumer subscription  messaging.
8. The STB /unique consumer subscription  must be compliant to the applicable Bureau of Indian Standards
9. The STBs /unique consumer subscription  should be addressable over the air to facilitate OTA software
upgrade.
10. The STBs/unique consumer subscription  with facilities for recording the programs shall have
international standard copy protection system
11. The STB /unique consumer subscription  should have a provision that fingerprinting  is never disabled.
12. The watermarking network logo for all pay channels shall be inserted at encoder end only .
13. DRM/SMS deployed should be able to send scroll messaging which should be only available in the lower
part of the screen.
14. DRM deployed should be able to geo tag STB/unique consumer subscription  deployed in the network for
security.
15. STB/un ique consumer subscription  should take all commands directly from DRM not from any

V. RAGHUNANDAN, Secy.
[ADVT. -III/4/Exty./423/2023 -24]
Note.1:  The principal re gulations were published in the Gazette of India, Extraordinary, Part III, Section 4, vide
notification No. 21 -4/2016 -B&CS dated 3rd March 2017 (1 of 2017).
Note. 2:  The principal regulations were amended vide notification No. 21 -6/2019 -B&CS dated 30th October 2019 (7
of 2019).
Note. 3:  The principal regulations were further amended vide notification No. 21 -5/2019 -B&CS dated 1st January
2020 (1 of 2020).
Note. 4:  The principal regulations were further amended vide notification No. RG -1/2/(3)/2021 -B AND CS(2 ) dated
11th June 2021 (1 of 2021).
Note. 5:  The principal regulations were further amended vide notification No. RG -1/2/(2)/2022 -B AND CS (2) dated
22nd November 2022 (2 of 2022).
Note. 6:  The Explanatory Memorandum explains the objects and reasons of the  Telecommunication (Broadcasting
and Cable) Services Interconnection (Addressable Systems) (Fifth Amendment) Regulations, 2023 ( 4 of 2023).
Explanatory Memorandum
Introduction and Background
1. TRAI notified the Telecommunication (Broadcasting & Cable) Ser vices Interconnection (Addressable System)
Regulation, 2017 on 03.03.2017 [hereinafter referred to as ―Interconnection Regulations 2017‖].  intermediate servers.
16. STB/unique consumer subscription while using IPTV infrastructure should not have feature to download
(direct or side download) any 3rd party App/ APK  and should not have access to any browser.
17. STB/unique consumer subscription  should not be able to access the authorization keys from any other
source except from the IPTV system through the IPTV closed network. DRM must ensure that the
authoriza tion keys are not received by the STB /unique consumer subscription  from any other source other
than the one specified by the IPTV system
18. No play store should be accessible for enabling download, etc. when STB/unique consumer subscription,
is functio ning in the IPTV network.
19. STB/unique consumer subscription  should have copy protection.
20. DPO system should have capability to maintain un -editable logs of all activity and configurations
including download or upgrade of IPTV services App (if any ) at STB/unique consumer subscription  end
21. The DRM should not allow delivering linear TV channels on Internet. The delivery of multi channel
television programmes should remain in a closed network within the device.
22. The STB/unique consumer subscr iption  should have forced messaging capability including forced finger
printing display.
23 The DRM hybrid STBs/unique consumer subscription  should be tested for the following prior to their
seeding in the subscribers‘ premises:
(a) System down testing
(b) Error messaging
(c) Negative user journey testing
(d) Device variance testing
(e) Destructive testing
(f) Application monitoring testing
(g) In -app monitoring testing

2. During the consultation undertaken to prepare the Audit Manual, certain comments and observations reflect some
issue s in the Schedule III of the Interconnection Regulations 2017.
3. Accordingly, Draft Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable
Systems) (Amendment) Regulations, 2019  [hereinafter referred to as the ―Draft Regulations‖] was issued on 27
August 2019. These Draft Regulations amended Schedule III of the Interconnection Regulations 2017, on the
following issues: -
i.      Digital Rights Management Systems
ii.     Transactional capacity of CAS and SMS system
iii.     Finge rprinting – Support for Visible and Covert fingerprinting in STBs
iv.     Watermarking network logo for all pay channels.
4. DRM is a systematic approach to  copyright  protection for digital media. The purpose of DRM is to prevent
unauthorized redistribution o f digital media and restrict the ways consumers can copy content they've purchased.
DRM products were developed in response to the rapid increase in online  piracy  of commercially marketed
material, which proliferated through the widespread use of  peer-to-peer file exchange programs. Typically, DRM
is implemented by embedding code that prevents copying, specifies a time period in which the content can be
accessed or limits the number of devices the media can be installed on. DRM technology focuses on making it
impossible to steal content in the first place, a more efficient approach to the problem than the hit -and-miss
strategies aimed at apprehending online poachers after the fact.
5. The Schedule III of the Interconnection Regulations 2017 does not provide for  the requirements / specifications of
DRM based systems. The Authority, during its consultations on Audit manual, received the feedback that owing
to its benefits the IPTV based DPOs are switching to DRM technology. It is necessary that the Audit regime
covers the DRM based networks and provides for enabling provisions for such operators. Accordingly, Draft
Regulations included DRM specifications in Schedule III.
6. During the consultation process, the Authority received numerous comments and suggestions from various
stakeholders on this issue. Numerous modification/additions were proposed by several stakeholders. Hence, the
Authority was of the opinion that system requirements for DRM shall be dealt with in a separate consultation
paper (refer para 34 of Expla natory Memorandum to the Interconnection (Amendment) Regulations, 2019 dated
30.10.2019).
7. The Authority was of the view that on the issue related to ―System Requirements for Digital Rights Management
System‖, extensive deliberations with industry stakehold ers is required.  Accordingly, the Authority constituted a
committee comprising of industry stakeholders to prepare and submit draft ‗System Requirement for Digital
Right Management (DRM)‘ to the Authority. The committee had representatives from the followi ng
firms/organisations/associations:
 Broadcast Engineering Consultants India Limited (BECIL)
 Indian Broadcasting and Digital Foundation (IBDF)
 News Broadcasters & Digital Association  (NBDA)
 All India Digital Cable Federation (AIDCF)
 Dish TV
 Tata Sky
 Bhart i Telemedia
 Sun Direct
 NXT Digital
 IIT Kanpur
 Andhra Pradesh State Fibernet Ltd
 Delinet Broadband
8. The Terms of Reference of the Committee, was to:
(i)   Study TRAI‘s Telecommunication (Broadcasting & cable) Services Interconnection (Addressable
System) Regulation, 2017 and its amendments (hereinafter called  “Interconnection Regulation 2017” ).

(ii)   Provide a report to the Authority on the ―System requirement for Digital Right Management (DRM)‖ to
be included in Schedule III of the Interconnection Reg ulation 2017.
9. The committee held several meetings. These meetings were facilitated by the Authority. After extensive
deliberations, the committee submitted a report on ―System requirement for Digital Right Management (DRM)‖
to be included in Schedule III o f the Interconnection Regulation 2017 to the Authority. The Authority conveys its
appreciation for the extensive work done by the committee.
10. Accordingly, TRAI issued a Consultation Paper  on ‗System Requirement for Digital Right Management (DRM)‘
in the for m of draft amendment in the Interconnection Regulation 2017 on 9th September 2022.  The comments of
the stakeholders were invited by 7th October 2022 and counter comments, by 21st October 2022.   On request of
the stakeholders, the deadline to submit the com ments was extended till 18th November 2022 for comments and
2nd December 2022 for counter -comments. Comments on the said consultation paper were received from twenty
one stakeholders and counter -comments were received from two stakeholders, which were uplo aded on TRAI
website. Subsequently, an Open House Discussion (OHD) was held on 24th February 2023. A few additional
comments were also received after OHD.
11. After taking into consideration the comments received from the stakeholders and in -house analysis, th e Authority
has finalized the Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems)
(Fifth Amendment) Regulations, 2023 (hereinafter referred to as the ―Fifth Amendment Regulations‖). The
subsequent paragraphs explain th e objects and reasons of the Fifth Amendment Regulations.
12. The DRM based IPTV systems are being deployed. As it is a developing ecosystem, the regulations may require
review on the basis of feedback or future developments. Accordingly, the Authority may co nsider to review these
regulations as and when considered necessary.
Date of implementation of these Regulations
13. In the  consultation paper on ―Draft Telecommunication (Broadcasting and Cable) Services Interconnection
(Addressable Systems) (Fourth Amendment ) Regulations, 2022‖ dated 9th September 2022 [hereinafter called
CP], the following was mentioned:
“(3) These regulations shall come into force from the date of their publication in the Official Gazette.”
14. During discussions with a few stakeholders, the st akeholders suggested that some time may be given to the
industry to comply with these Regulations. Accordingly, the Authority is of the view that these regulations shall
come into force from the date of their publication in the Official Gazette provided th at for the existing systems,
the provisions of these regulations shall apply after three months from the date of their coming into force.
Digital Rights Management (DRM) System Requirements
15. In the CP, the following was mentioned:
“The term DRM, herein, r efers to the management of the encryption systems for, inter -alia, providing the
functionality of CAS and SMS for the Internet Protocol Television (IPTV) service provider under these
regulations.”
16. In response, an association proposed that DRM System requir ements ―for IPTV services‖ should be specifically
mentioned in the introduction and background to the Draft Fourth Amendment as well as captioned in Draft
Schedule -X of the Draft Fourth Amendment. They mentioned that the Draft Fourth Amendment should clear ly
specify that these requirements are in the context of DRM systems deployed by DPOs providing IPTV services.
The words ―DPOs providing IPTV services‖ be suitably incorporated in Draft Fourth Amendment and Draft
Schedule -X. The association further opined that scope of Consultation Paper, Draft Fourth Amendment and Draft
Schedule -X is to be restricted to IPTV services, which for clarity, must exclude any over -the-top (OTT) services
inter-alia for jurisdictional issues.
17. A few stakeholders and an association opined that the term DRM should refer to the management of the
encryption systems for, inter -alia, providing the functionality of only CAS for the IPTV service provider under
these regulations.
Analysis:
18. DRM mainly provides management of the encryption sy stems for, inter -alia, providing the functionality of CAS
for IPTV service. Further, the regulation already has separate section for ‗DRM requirements in so far as they
related to subscriber management systems (SMS) for IPTV services‘. Therefore, the Autho rity is of the view that
the word ‗SMS‘ may be removed from explanation of DRM. Accordingly, modification has been carried out in
the regulation.

(C) Overall architecture / system requirements and certification for IPTV service
19. In the CP, the following wa s mentioned:
“(a) Retransmission of channels shall be over a closed network owned and controlled by DPO for electronic
delivery of audio video stream of linear channels using Internet Protocol through an encrypted, point -to-
point system architecture to set  top boxes located within a subscriber’s premises. For the avoidance of doubt,
IPTV shall not include any electronic delivery for receipt and viewing via (i.e., directly accessible via) the
Internet/world wide web/OTT. ”
20. In response, one association and a f ew stakeholders proposed that retransmission of channels shall be over a
closed network owned and/or controlled by DPO for electronic delivery of audio video stream of linear channels
using Internet Protocol through an encrypted, point -to-point system arch itecture to set top boxes located within a
subscriber‘s premises. For the avoidance of doubt, IPTV shall not include any electronic delivery for receipt and
viewing via (i.e., directly accessible via) the Internet / world wide web/OTT.
21. A few stakeholders a nd an association suggested removal of last line of (C) (a). One stakeholder suggested IPTV
shall not include any electronic delivery for receipt and viewing via (i.e., directly accessible via) the Internet /
world wide web/OTT. They opined that it is prac tically not feasible for any DPO to own the complete network.
22. One association opined that retransmission of channels should be only over the closed network that is owned,
controlled, and managed by the relevant DPO. IPTV Services should neither be accessib le through nor touch
public/open Internet. DPO should not be allowed to sub -license the DRM and/or any rights granted to such DPO
by the broadcaster. They further mentioned that at present, there are no guidelines issued by MIB regarding
infrastructure sha ring between IPTV operators, and as such, there are inter -alia jurisdictional issues concerning
infrastructure sharing between IPTV operators. It is premature to include requirements relating to infrastructure
sharing in the Draft Fourth Amendment / Draft Schedule -X since, the same appears to be a foregone conclusion
of TRAI on these aspects. One stakeholder opined that an option should be considered for introduction of Soft
STBs (App based) for running IPTV services.
Analysis:
23.  The IPTV operators are  enjo ined to comply with extant MIB Guidelines and TRAI Regulations. Appropriate
provisions already exist in guidelines/ regulations. Therefore, after due consideration this clause has been
removed .
(D) DRM Requirements in so far as they relate to subscriber ma nagement systems (SMS) for IPTV
services:
Table 1 (1.) of CP
24. In the CP, the following was mentioned:
“There shall not be any data mismatch between DRM and SMS.  Maximum mismatch based on subscription base
may be allowed as mentioned below:
(1) Must be less tha n 0.20% for subscriber base up to 100000 subs (0 to 200 for subscriber base of up to
100000)
(2) Must be less than 0.04% for subscriber base up to 1000000 subscribers (0 to 400 for subscriber base of up to
1000000)
(3) Must be less than 0.01% for subscriber base a bove 10000000 subscribers (0 to 1000 for subscriber base of
up to 10000000)
The data between both the systems shall be reconciled on a monthly basis. The reconciliation report shall be
stored along with the system data for a minimum of 2 years or  at least two audit cycles, or as per Schedule III
whichever is later.”
25. In response, a few stakeholders and an association opined that mismatch between DRM and SMS cannot be
matched with low difference. Because number of users (LCO) and number of sessions used in SM S is very high
and in 1st week of every month there will be huge commands travelling via API and SMS need to handle 2 or 3
DRM/CAS. In such scenario there is possible of mismatch, so making the mismatch 1% will be useful for DPO.
An association opined that  it is imperative that a period of three (3) years be prescribed by Authority for retention
of data and records so as to inter -alia ensure that the broadcaster led audits can be meaningfully conducted.
26. On the other hand, a few stakeholders opined that the mismatch must be 0.5% as similar in cable TV. One
stakeholder mentioned that the provided guidelines are really appreciated and the same should also be enforced to
the other DPO platforms too.

Analysis:
27. Regarding mismatch percentage, some stakeholders hav e opined that the limits should be increased, however, the
Authority is of the view that these percentages may not be modified at this stage and the case may be reviewed at
a later stage.
28. With respect to retention period for data and records, it may be not ed as per Schedule III of the Interconnection
Regulations 2017 (as amended), the annual Audit as caused by Distributor under regulation 15 (1) shall be
scheduled in such a manner that there is a gap of at -least six months between the audits of two consecut ive
calendar years. Further, there should not be a gap of more than 18 months between audits of two consecutive
calendar years. In this regard, it has been brought to the notice of TRAI that many DPOs submit their DPO
initiated audit reports (under clause 15(1) of TRAI‘s Interconnection Regulations) to the broadcasters six (6) to
eighteen (18) months after they receive the audit report from their respective auditors. By the time the broadcaster
analyses the same, highlights relevant observations/discrepanci es, and/or decides to conduct broadcaster caused
audit in terms of Clause 15(2) of Interconnection Regulations, there is already a year‘s (or sometimes more)
delay, which diminishes the relevance of audit report as well as allows DPOs to claim unavailabili ty of
data/records relying on TRAI‘s requirement to maintain data/records only for two (2) years. This, inter -alia,
amplifies the problem and hinders detection of true and correct subscriber numbers. In this regard, the Authority
is of the view that transp arency is utmost important in the entire value chain and increasing the period of record
retention from 2 to 3 years, will improve the overall transparency, assist in curbing the menace of under reporting
subscribers and improve the effectiveness of broadc aster caused audit prescribed in 15(2) of Interconnection
Regulation 2017. Same suggestion has been received for multiple places in the Regulation. Accordingly,
modifications have been made in the regulation.
Table 1 (2.)  of CP
29. In the CP, the following was  mentioned:
“Password Policy Creation for Users : SMS shall have a defined password policy, with minimum length criteria
and composition (upper and lower -case characters, numeric, alphabets or special characters), forced password
changes or any other approp riate mechanisms or combinations thereof. ”
30. In response, one stakeholder suggested that above mentioned clause may be modified to read as follows:
Password Policy Creation for Users: SMS shall have a defined password policy, with minimum length criteria and
composition (upper and lowercase characters, numeric, alphabets or special characters), forced  password changes
or any other appropriate mechanisms or combinations thereof or alternatively user account has to be locked/paired
to the Mac Id of the STB or the Customer Premises Equipment (CPE).
Analysis:
31. Since Mac id of the STB or the CPE are unique and if they are paired or locked with the user account, the support
for the password validation and recovery for users may not be required. Therefore, the Author ity is of the view
that an alternate arrangement wherein user account has to be locked/paired to the Mac Id of the STB or the CPE,
may also be permitted. Accordingly, modifications have been made in the regulation.
Table 1 (4.)  of CP
32. In the CP, the followi ng was mentioned:
“All activation and deactivation of STBs shall be done with the commands of the SMS integrated with
the DRM .”
33. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘. They opined  that IPTV can be provided as an application based with all security required under
TRAI regulation.
Analysis:
34. With technological developments content can be viewed using application based services provided such
arrangement meets extant licensing/regulator y framework. Therefore, the Authority is of the view that App based
services, may also be permitted. Soft STBs (App based) may also be used for running IPTV services.  In such
cases, the unique id for each subscriber is required. In all such cases, STB or the CPE should have a unique Mac
id that should be paired or locked with a user account. In view of above, the Authority is of the view that in place
of ‗STBs‘, the words ‗STBs/unique consumer subscription‘ would be more appropriate to use. Similar/same
suggestion has been received from a few stakeholders at multiple places in the Regulation.   Accordingly,
modifications have been made in the regulation.
Table 1(5.)  of CP
35. In the CP, the following was mentioned:
“Necessary and sufficient methods shall be put  in place so that each activation and deactivation of STBs is
reflected in the reports generated from the SMS integrated with the DRM and vice versa .”

36. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘. Further, another stakeholder suggested the following ‗Necessary and sufficient methods shall be put
in place so that each activation and deactivation of STBs is reflected in the reports generated from the SMS
integrated with the DRM and DRM Se ssion logs should be able to validate the access of the channels between
period of activation and deactivation of the STBs.‘
Table 1(6.)  of CP
37. In the CP, the following was mentioned:
“DRM and SMS should be able to activate or deactivate services and/or ST Bs of the subscriber base of the
distributor within 24 hours.”
38. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘.
Table 1(7.)  of CP
39. In the CP, the following was mentioned:
“The SMS shall be independently capable of generating, recording, and maintaining logs, for the period of at
least immediately preceding two (2) consecutive years, corresponding to each command executed in the SMS
including but not limited to activation and deactivation com mands.”
40. In response, an association suggested the period of at least immediately preceding three (3) consecutive years,
instead of two (2) consecutive years. Further, they mentioned that the time period for record retention throughout
the Draft Regulations  2022 has been prescribed as two (2) years instead of proposed three (3) years as was
submitted in the DRM Committee Report. The three (3) years‘ time period was inter -alia suggested in order to
ensure that the data for the preceding three (3) years is ava ilable for the purposes of broadcaster led audits
prescribed under clause 15 (2) of the Interconnection Regulations. The Interconnection Regulations prescribe a
period of two(2) years for data/record retention, which is insufficient and factors period of l imitation
contemplated under the provisions of the Consumer Protection Act. However, it completes overlooks the period
of limitation contemplated under the Limitation Act, which is the only statute relevant from the perspective of
broadcaster -DPO relations hip. They further mentioned that by the time the broadcaster led audit is conducted, the
prescribed period of two (2) years for data/ record retention is already over. Therefore, the period for retention of
data in the Draft Fourth Amendment be prescribed for at least three (3) years.
Table 1 (8) (j)  of CP
41. In the CP, the following was mentioned:
“The SMS should be computerized and capable of recording all logs including information and data concerning the
subscribers such as:……..
(j)      Unique STB number”
42. In response, a stakeholder suggested that the words ‗STB number‘ should be replaced with ‗STB number/user
name‘. They opined that DRM and Middleware systems work with usernames which are more user friendly than
STB numbers.
Table 1 (9.)  of CP
43. In the CP, t he following was mentioned:
“The SMS should be capable of:
(a) Viewing and printing of historical data in terms of the activations and the deactivations of STBs.
(b) Locating each and every STB and VC/MAC ID installed at city and state level.
(c) Genera ting historical data of changes in the subscriptions for each subscriber and the corresponding source of
requests made by the subscriber.”
44. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘.
Table 1 (10.)  of CP
45. In the CP, the following was mentioned:
“The SMS should be capable of generating reports, at any desired time including about:
(a) The total number of registered subscribers.

(b) The total number of active subscribers.
(c) The total number of temporary suspended subscribers.
(d) The total number of deactivated subscribers.
(e) List of blacklisted STBs in the system.
(f) Channel and bouquet wise monthly subscription report in the prescribed format.
(g) The names of the channels for ming part of each bouquet.
(h) The total number of active subscribers subscribing to a particular channel or bouquet at a given time.
(i) The name of a -la carte channel and bouquet subscribed by a subscriber.
(j) The ageing report for subscription of a particular channel or bouquet.”
46. In response, a few MSOs and one association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘.
Table 1 (13.)  of CP
47. In the CP, the following was mentioned:
“If there is active infrastructure sharing then, DPO shall declare the sharing of the DRM and the SMS deployed
for distribution of channels. In case of deployment of any additional DRM/SMS, the same should be notified to the
broadcasters by the distributor.”
48. In response, one association opined that at presen t, there are no guidelines issued by MIB regarding infrastructure
sharing between IPTV operators, and as such, there are inter -alia jurisdictional issues concerning infrastructure
sharing between IPTV operators. It is premature to include requirements rela ting to infrastructure sharing in the
Draft Fourth Amendment / Draft Schedule -X since, the same appears to be a foregone conclusion of TRAI on
these aspects.
Analysis
49. Regarding infrastructure sharing amongst IPTV operators, it may be noted that Ministry o f Information and
Broadcasting (MIB) has not yet issued any guidelines in this regard. TRAI may forward its recommendations to
MIB on this issue, after due consultation process. However, the Authority is of the view that Interconnection
Regulation should h ave an enabling provision to promote infrastructure sharing amongst IPTV operators, which is
subject to the MIB‘s ‗Guidelines on infrastructure sharing for IPTV operators‘, as and when permitted by MIB.
Same suggestion has been received for multiple places  in the Regulation. Accordingly, modifications have been
made in the regulation.
Table 1(14.) of CP
50. In the CP, the following was mentioned:
“SMS shall have a provision to generate synchronization report, with date and time, with the minimum fields as
listed below:
(a) STB Number (or in case of card -less system, chip ID or MAC ID number of the STB)
(b) Product Code pertaining to à -la-carte channels and bouquets available on the platform
(c) Start Date of entitlement
(d) End Date of entitlement
(e) Status of STB (active/Inac tive)”
51. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘.
Table 1(15.)  of CP
52. In the CP, the following was mentioned:
“ The file output of DRM shall be processed by SMS system to compare and generate a 100% match or mismatch
error report.”
53. In response, one stakeholder opined that clarification is needed on File output formats required from DRM. The
stakeholder has further mentioned that if not regulated, there may arise different versions of t he clause mentioned.

Analysis:
54. TRAI has issued the Telecommunication (Broadcasting and Cable) Services Digital Addressable Systems Audit
Manual [hereinafter called Audit Manual] on 8th November 2019. Similarly, TRAI may issue Audit Manual for
audits of D RM systems. Therefore, the issue related to file output formats related to DRM systems may be dealt
with at that stage.
Table 1 (16.) of CP
55. In the CP, the following was mentioned:
“Channel/Bouquet management:  SMS shall support the following essential requ irements:
(a) Create and manage all channels and bouquets along with the relevant details such as name, tariff,
broadcaster, or DPO bouquet, etc.
(b) Manage changes in the channel/bouquet, as may be required, from time to time.
(c) Link the Products IDs  for à -la-carte channels and bouquets (Single and Bulk) created in DRM with the
product information being managed in SMS, for smooth working of SMS and DRM integration.
(d) Management of historical Data of Product name, i.e., Broadcasters (name), maximum retail price (MRP),
distributor retail price (DRP).”
56. In response, one stakeholder suggested an amendment that SMS creates and manages packages based on Product
ID and composition provided from DRM. They further mentioned that DRM API‘s cannot allow Package s to be
directly be created/modified from SMS subject to DRM database security.
Analysis:
57. The Authority is of the view that SMS, in synchronisation with DRM on real time basis, should support the
following essential requirements (amongst other essential re quirements as specified in the regulation): Create and
manage relevant product ID for all channels and bouquets along with the relevant details such as name, tariff,
broadcaster, or DPO bouquet, etc.
Table 1 (17.)  of CP
58. In the CP, the following was mentio ned:
“Network Capacity Fee (NCF) Policy Creation:  SMS shall support all NCF related requirements mandated by
the applicable tariff order.”
59. In response, one stakeholder opined that the Tariff orders need to be finalized and enforced by the authority, since
there is a lot of ambiguity regarding this. The broadcasters are enforcing the tariff as per their convenience and
some broadcasters are even seeking for minimum guarantee commitment to provide the IRD to the IPTV
provider, which is against creating a play ing field for the DPOs.
Analysis:
60. It is binding on the service providers to comply with TRAI‘s Regulation/tariff order/ directions/Order, etc.
Table 1 (19.)  of CP
61. In the CP, the following was mentioned:
“Management of Logs : ….
(b) SMS shall have the provi sion of generating the user activity log report to enable tracking users’ work history.
It shall not be allowed to delete the records from the log.”
62. In response, one stakeholder suggested that the word ‗SMS‘ should be replaced with ‗SMS/DRM‘. They further
opined that DRM maintains the session logs whenever a user views a channel including the time stamp. These
logs facilitate the viewership analysis and provides validation for the channel access as per the user‘s
subscription.
Analysis:
63. In the regulation t here is already a provision related to DRM maintaining proper logs, accordingly no
modification has been made in the Regulation.
Table 1 (22.)  of CP
64. In the CP, the following was mentioned:
“STB and MAC ID shall be paired from the SMS to ensure security of channel (applicable for DRM with pairing
facility).”

65. In response, one stakeholder suggested that STB/Username and MAC ID shall be paired from the SMS to ensure
security of channel.
Table 1 (23.)  of CP
66. In the CP, the following was mentioned:
“The SMS shall  be capable of individually addressing subscribers, for the purpose of generating the reports, on
channel by channel and STB by STB basis.”
67. In response, a few stakeholders and an association suggested generating the reports, on channel by channel and
STB/M AC ID by STB/MAC ID basis. They opined that for app, it can be identified with MAC ID or with its
unique ID.
Table 1 (24.)  of CP
68. In the CP, the following was mentioned:
“SMS should have a facility to carry out monthly reconciliations of channels/ala carte and bouquet (with their
respective ID created in SMS with DRM) and the variance report should be available in both DRM and SMS logs
and made available during audits.”
69. In response, one stakeholder opined that SMS should have a facility to carry out monthly reconciliations of
channels/ala carte and bouquet (with their respective ID created in SMS with DRM) and the variance report
should be available from the DRM and SMS logs and made available during audits.
Analysis:
70. The Authority accepts the suggestion mad e by stakeholder.
Table 1 (26.)  of CP
71. In the CP, the following was mentioned:
“Audit -related requirements :
SMS should have the capability to capture below -mentioned information that may be required for audit and
otherwise: …..
(c) STB related:
(i) Change in location history
(ii) Change in status (Active/Damaged/Repaired/Replaced)”
72. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘.
Table 1 (27.)  of CP
73. In the CP, the following was mentioned:
“User Authentication:  SMS should have the capability to authenticate its subscribers through registered mobile
number (RMN) through one -time password (OTP) system.”
74. In response, one stakeholder desired to know if the above clause is to enable logging in fro m other device to
check subscription status or to use OTP to activate the box.
Analysis:
75. As mentioned above, one stakeholder has desired to know if the above clause is to enable logging in from other
device to check subscription status or to use OTP to act ivate the box. In this regard, it is clarified that user
authentication is required not only to activate any subscription but also to continue using it as per subscription
terms and conditions.
Table 1 (28.)  of CP
76. In the CP, the following was mentioned:
“SMS should have the provision to support the following additional requirements:
(a) List of à -la-carte channels and bouquets, digital headend (DHE) and Zone -wise: Provision to support/manage
Zone/ Sub -Headend -wise list of à -la-carte channels and bouquets,  in sync with the list available in DRM. ……”
77. In response, one stakeholder enquired the meaning of ‗zone‘.

Analysis:
78. Since the concept of zone does not find a mention in any Regulation/Tariff order, the words ‗zone‘ or ‗Zone -wise‘
has been removed from the  regulation.
Additional clause
79. An association suggested insertion of the following additional clause,
―It shall be mandatory for SMS to have backup servers and logs of all activities carried out in main server shall be
concurrently copied into the cloud -based backup servers, in an automated manner without any manual
intervention, of reputed companies viz., AWS, Oracle, Microsoft Azure, Google cloud.
Provided that a log of all such instances shall be maintained along with date and time stamp, where the
backup server has been used as the main server:
Provided further that the main and backup server shall always be in sync with regard all data, such as
subscription data, STB UA/MAC ID details, entitlement level information, etc.
Provided further that it sha ll be permissible for vendors of servers to provide data / records to TRAI, MIB,
relevant empaneled auditor and to relevant broadcasters.‖
Analysis
80. In order to avoid any loss of logs and activities, it is imperative that backup servers are there for SMS da ta. This
will also facilitate the audit process. Accordingly, provisions have been made in the Regulation.
(E) DRM Requirements for conditional access by subscribers and encryption for IPTV services
Table 2 (2.)  of CP
81. In the CP, the following was mention ed:
“DRM shall ensure all logs are un -editable, stamped with date and time of all transactions (all activations,
deactivation, channel authorization/assignment and un -authorization / de -assignments and change in MAC
ID/STB). The DRM shall not allow alterin g or modification of any logs. There shall be no facility for the
distributor/users to purge logs.”
82. In response, one stakeholder suggested to remove un -editable and not allowing altering the logs. They mentioned
that this is possible in theory to generate fully protected logs using technologies like blockchain or ledger
databases. However, this is a very expensive approach that the regulator shouldn't require. The DPO and DRM
provider should enforce controlled access to the logs, so only authorized personne l can access the logs. Only the
logging application should have the writer write the logs. All other users can only read the logs.
83. Another stakeholder opined that DRM shall ensure all logs are uneditable, stamped with date and time of all
transactions (all  session logs of the users, channel wise, date wise with user id or mac id should be available). The
DRM shall not allow altering or modification of any logs. There shall be no facility for the distributor/users to
purge logs. Provision for validation of s ession logs with subscription status should be available via middleware or
an equivalent software.
Analysis:
84. The Authority is of the view that it is necessary to ensure that the logs are un -editable and stamped with date and
time of all transactions. In c ase tempering of logs is permitted then it will defeat the whole purpose of maintaining
logs. Accordingly, no modifications have been proposed in the regulation.
Table 2(3.)  of CP
85. In the CP, the following was mentioned:
“DRM deployed do not have facility to activate and deactivate a Set Top Box (STB) directly from the Graphical
User Interface (GUI) terminal of DRM. All activation and deactivation of STBs shall be done with the commands
of the SMS integrated with DRM. The DRM shall be integrated with the SM S in a manner that ensures security of
the channel.”
86. In response, a few stakeholders and an association suggested that DRM deployed do not have facility to activate
and deactivate a Set Top Box (STB)/MAC ID (APP) directly from the Graphical User Interface (GUI) terminal of
DRM. All activation and deactivation of STBs/APP shall be done with the commands of the SMS integrated with
DRM. The DRM shall be integrated with the SMS in a manner that ensures security of the channel.  Another
stakeholder opined that i n some cases, like for testing purposes, the UI or other means should allow authorized
personnel to manage the client devices.

Analysis:
87. All activation and deactivation of STBs/unique consumer subscription must be done with the commands of the
SMS integra ted with DRM. However, the Authority is of the view that some provisions may be kept for specific
testing purposes. It is pertinent to ensure that such feature may be available only for specific testing. The
command or access for such feature may be availa ble with the highest system administration password. In all
such cases a separate log file of such commands must be maintained. Accordingly, modifications have been made
in the regulation.
Table 2 (4.)  of CP
88. In the CP, the following was mentioned:
“The SMS  and the DRM should be integrated in such manner that activation and deactivation of STB happen
simultaneously in both the systems.
Explanation: Necessary and sufficient methods shall be put in place so that each activation and deactivation of
STBs is refl ected in the reports generated from the DRM.”
89. In response, a few stakeholders and an association suggested that the SMS and the DRM should be integrated in
such manner that activation and deactivation of STB/MAC ID happen simultaneously in both the systems .
Explanation: Necessary and sufficient methods shall be put in place so that each activation and deactivation of
STBs/APP is reflected in the reports generated from the DRM.
90. Another stakeholder suggested that the SMS and the DRM should be integrated in su ch manner that activation
and deactivation of STB are synchronized in real time.
Analysis:
91. The Authority is of the view that SMS and the DRM should be integrated in such manner that activation and
deactivation of STB happen simultaneously in both th e systems and both the systems are synchronized in real
time.
Table 2(6.)  of CP
92. In the CP, the following was mentioned:
“The DRM deployed should be able to support both carded as well as card -less STBs for any provisioning.”
93. In response, a few stakeholders  and an association suggested that the word ‗STBs‘ should be replaced with ‗STBs
and APP based‘. Another stakeholder opined that it is irrelevant for DRM which is cardless by its nature. Another
stakeholder suggested that the DRM deployed should be able to  support both carded card -less STBs & Smart TV
for any provisioning.
Table 2 (7.)  of CP
94. In the CP, the following was mentioned:
“The DRM deployed should be able to generate, record, maintain independent reports and logs for verification
purpose during aud its corresponding to each command executed in the DRM issued by the SMS integrated
with the DRM for last two (2) years minimum. The reports must have date and time stamp. Proposed reports
should include:…….”
95. In response, one stakeholder suggested that the clause may additionally mention that MSO can have these
transactional logs exported to an external storage system ensuring that it is available in raw format without any
change for the period of at least immediately preceding two (2) consecutive years, cor responding to each
command executed in the SMS including but not limited to activation and deactivation commands. As mentioned
earlier an association opined that it is imperative that a period of three (3) years be prescribed by Authority for
retention of data and records so as to inter -alia ensure that the broadcaster led audits can be meaningfully
conducted.
Table 2 {7(a)}  of CP
96. In the CP, the following was mentioned:
“Unique active STB count as well as MAC ID wise on any desirable date”
97. In response, one stakeholder suggested Unique active STB count as well as Unique MAC ID/User ID/DRM ID
wise on any desirable date.
Table 2 {7(b)}  of CP
98. In the CP, the following was mentioned:
“Unique bouquet/channel active for a specific STB on any desirable date”

99. In response, one stakeholder suggested unique channel active for a specific STB/User on any desirable date.
Analysis:
100. It is understood that some DRM do not have provision to maintain bouquet information. In this regard, the
Authority is of the view that bouquet  information is required to be maintained in the DRM for verification and
reconciliation of data. The Authority has already specified that these regulations should come in to force after
three months from the date of publication of these regulations in the  Official Gazette. Therefore, in case this
facility does not exist in some of the existing DRM then the existing service providers should get this feature
developed in the DRM within these 3 months. Same suggestion has been received for multiple places in the
Regulation. Accordingly, modifications have been made in the regulation.
Table 2 {7(c)}  of CP
101. In the CP, the following was mentioned:
“MAC ID wise activation -deactivation report for service requests”
102. In response, one stakeholder suggested MAC ID/User ID wise Channel viewership report for service requests.
Table 2{7(d)}  of CP
103. In the CP, the following was mentioned:
“Any alteration in bouquet and/or channels configured in DRM.”
104. In response, one stakeholder any alteration in bouquet and/or channels confi gured in DRM if the facility is
available in DRM.
Table 2 {7(e)}  of CP
105. In the CP, the following was mentioned:
“Blacklist STB report”
106. In response, one stakeholder opined that Blacklist STB should not have access/session log in the DRM. This
clause can be r emoved also.
Analysis:
107. It is learnt that Blacklisting STB is done only in SMS. When it is blacklisted in SMS it will not send the request
to DRM for viewer ship so no activity can be recorded in DRM. Therefore, the Authority is of the view that
Blacklist STB/unique consumer subscription report may be made a desirable feature and it should not be
mandated at this stage. Accordingly, modifications have been made to the regulation.
Table 2 {7(f)}  of CP
108. In the CP, the following was mentioned:
“Product code per taining to channels/ bouquets available on the platform.”
109. In response, one stakeholder opined that product code pertaining to channels should be available in DRM.
Table 2 {7(g)}  of CP
110. In the CP, the following was mentioned:
“Channel/bouquet authorization/ assignment to STB along with start date and end date of entitlement”.
111. In response one stakeholder suggested Channel Viewership Access by STB /User for a particular date / week /
a period (from date to date). A few stakeholders and an association suggested that the word ‗STB‘ should be
replaced with ‗STB/Mac ID‘.
Table 2 {7(h)}  of CP
112. In the CP, the following was mentioned:
“STB -VC pairing / de -pairing (if applicable)”
113. In response, one stakeholder suggested STB -VC pairing / de -pairing or User id - Mac-id Pairi ng / de -pairing (if
applicable) in SMS/DRM.
Analysis:
114. The Authority accepts the suggestion made by stakeholder.

Table 2 {7(i)}  of CP
115. In the CP, the following was mentioned:
“STB activation / de -activation”
116. In response, one stakeholder opined that Session  Log validation should be possible for each active subscribed
channel per user during subscription period of the user for any channel.
Table 2 {7(j)}  of CP
117. In the CP, the following was mentioned:
“Channels assignment to STB”
118. In response, one stakeholder o pined that DRM should not have facility for assignment of channel / bouquets to
STB/User. If the facility is available, the corresponding logs should be available. A few stakeholders and an
association suggested that the word ‗STB‘ should be replaced with ‗STB/Mac ID‘.
Table 2 {7(k)}  of CP
119. In the CP, the following was mentioned:
“Report of the activations or the deactivations of a particular channel for a given period.”
120. In response, one stakeholder suggested that report of the activations or the deactivatio ns of a particular channel
for a given period available in SMS should be able to validate the session logs available in DRM.
Table 2 {7(l)} of CP
121. In the CP, the following was mentioned:
“The total number of registered subscribers.”
122. In response, one stakeh older suggested that the clause should be the total number of registered subscribers if
the DRM has the facility to register subscribers.
Analysis:
123. The same suggestion has been received for multiple places in the Regulation. The Authority does not agree
with the stakeholder comment.
Table 2 {7(n)}  of CP
124. In the CP, the following was mentioned:
“The total number of temporary suspended subscribers.”
125. In response, one stakeholder suggested that the clause should be the total number of temporary suspended
subscr ibers if the subscribers have registration facility in the DRM.
Table 2{7(o)}  of CP
126. In the CP, the following was mentioned:
“The total number of deactivated subscribers.”
127. In response, one stakeholder suggested that the clause should be the total number of deactivated subscribers if
the registration of subscribers is available in DRM
Table 2{7(p)}  of CP
128. In the consultation paper on ―Draft Telecommunication (Broadcasting And Cable) Services Interconnection
(Addressable Systems) (Fourth Amendment) Regulations,  2022‖ dated 9th September 2022, the following was
mentioned:
“List of blacklisted STBs in the DRM.”
129. In response, one stakeholder opined that the clause should be list of blacklisted STBs in the DRM if the
registration of subscribers is available in DRM. A nother stakeholder suggested that the word ‗STBs‘ should be
replaced with ‗STBs/Mac ID (APP)‘.
Table 2 {7(q)}  of CP
130. In the CP, the following was mentioned:
“Channel and bouquet wise monthly subscription report in the prescribed format.”

131. In response, one st akeholder suggested Channel and User wise monthly viewership report in the prescribed
format.
Table 2{7(r)}  of CP
132. In the CP, the following was mentioned:
“The names of the channels forming part of each bouquet.”
133. In response, one stakeholder suggested that the clause should be the names of the channels in relation to their
names registered in SMS.
Table 2{7(s)}  of CP
134. In the CP, the following was mentioned:
“The total number of active subscribers subscribing to a particular channel or bouquet at a given time .”
135. In response, one stakeholder suggested that the clause should be the total number of active subscribers
subscribing to a particular channel at a given time.
Table 2 {7(t)}  of CP
136. In the CP, the following was mentioned:
“The name of a -la carte channel an d bouquet subscribed by a subscriber.”
137. In response, one stakeholder suggested that the clause should be the name of the channels per user viewership
records with respect to subscription status of a subscriber.
Table 2{7(u)}  of CP
138. In the CP, the following was mentioned:
“The ageing report for subscription of a particular channel or bouquet.”
139. In response, one stakeholder suggested that the clause should be the ageing viewership report of a particular
channel for a particular time. Another stakeholder opined that much of this belongs to the Control Plane that
drives the DRM and not the DRM per se.
Table 2 (8)  of CP
140. In the CP, the following was mentioned:
“DRM deployed should be able to tag and blacklist the STB independently in case of any piracy.”
141. In response , one association suggested that the word ‗STB‘ should be replaced with ‗STB &VC‘. A few
stakeholders and an association suggested that the word ‗STB‘ should be replaced with ‗STBs/Mac ID (APP)‘.
Another stakeholder suggested that the clause should mention  that DRM deployed should not have any facility
to activate the blacklisted STB.
142. Another stakeholder enquired about the word ‗independently‘. They further opined that DRM by itself can't
detect piracy, it should be notified by some other parts of the ecos ystem about pirate devices that need to be
blacked out.
Table 2 (11)  of CP
143. In the CP, the following was mentioned:
“The DRM should be capable of generating, recording and preserving unedited data / logs for at least two
consecutive years for each command e xecuted through the DRM, including logs of each command of the SMS
integrated with the DRM.”
144. In response, one stakeholder opined that it's about the entire ecosystem and not DRM itself. Keeping not -
editable logs for several years incurs very significant co sts.
Table 2 (13)  of CP
145. In the CP, the following was mentioned:
“DRM shall not support carriage of channel with same name or nomenclature in the distributor’s network
served by each headend under more than one LCN, and another channel descriptor. Further, each channel
available in DRM shall be uniquely mapped with channels available in SMS.”
146. In response, a stakeholder opined that DRM doesn't deliver channels and it is not aware of the channel names,
LCN, etc. Another stakeholder suggested that the clause sh ould mention that DRM shall not support carriage of

channel with same name or nomenclature in the distributor‘s network served by each headend under more than
one instance, and another channel descriptor. Further, each channel available in DRM shall be uni quely
mapped with channels available in SMS.
Analysis:
147. As per sub regulation 2 of Regulation 18 of the Interconnection Regulation 2017 (as amended), it shall be
mandatory for the distributor to place all the television channels available on its platform in  the electronic
programme guide, in such a manner that all the television channels of a particular language in a genre are
displayed together consecutively and one television channel shall appear at one place only. Further as per sub
regulation 3 of Regula tion 18 of the Interconnection Regulation 2017, every distributor of television channels
shall assign a unique channel number for each television channel available on the distribution network. Since
above provisions already exist in the Interconnection Reg ulation 2017, the Authority is of the view that the
above clause 13 of Table 2 proposed in the CP should be deleted.
Table 2(14)  of CP
148. In the CP, the following was mentioned:
“DRM shall be capable of adding/modifying channels/bouquets as may be required on  real time basis in line
with the activity performed in SMS.”
149. In response, one stakeholder suggested that DRM shall be integrated with SMS in such a way that
addition/modification of channels/bouquets in SMS are automatically synced to the DRM on real -time.
Another stakeholder opined that it probably doesn't belong to DRM. Another stakeholder suggested that DRM
shall be capable of executing SMS requests for channels as may be required on real time basis in line with the
activity performed in SMS.
Table 2(1 5) of CP
150. In the CP, the following was mentioned:
“DRM should support only agreed DPO’s branded/proprietary and DPO’s supplied business model for
STBs.”
151. In response, a few MSOs and an association opined that DPOs should not be restricted to use only STB. So ,
STBs/APP based should be permitted. Another stakeholder suggested that DPO should deploy and activate
only the approved branded/proprietary STBs which are tested as per the technical Audit Manual and DPO‘s
should include the STB models in their Annexure -3 declaration and should submit the updated Annexure -3
declaration if any new model STB is deployed for the viewership of pay channels.
Analysis:
152. In the view of the Authority, DRM should be so configured for specific type of STB/unique consumer
subscriptio n, that are procured and configured by the DPO. The DRM should not enable working/operation of
any other type/brand/make of STB/unique consumer subscription, in the network.
Table 2 (16)  of CP
153. In the CP, the following was mentioned:
“When infrastructure sh aring is available, in such cases DRM shall be capable to support multiple DPOs.”
154. In response, one association opined that at present, there are no guidelines issued by MIB regarding
infrastructure sharing between IPTV operators, and as such, there are int er-alia jurisdictional issues concerning
infrastructure sharing between IPTV operators. It is premature to include requirements relating to infrastructure
sharing in the Draft Fourth Amendment / Draft Schedule -X since, the same appears to be a foregone con clusion
of TRAI on these aspects.
Table 2 (17)  of CP
155. In the CP, the following was mentioned:
“DRM should support content protection and usage rules enforcement for B2C model.”
156. In response, one stakeholder suggested that DRM should support content protectio n and usage viewership data
for B2C model. Another stakeholder enquired the meaning of "usage rules enforcement for B2C Model".
Another organization also sought clarification regarding the usage rules.
Analysis:
157. The Authority is of the view that DRM should  support content protection.

Table 2 (18)  of CP
158. In the CP, the following was mentioned:
“DRM should be capable of handling at least 3 million license transactions per minute.”
159. In response, one stakeholder suggested that DRM should be capable of handling at  least 10000 license
transactions per minute subject to the DPO subscriber base. Another stakeholder suggested that DRM should
be capable of handling at least % of license transactions per minute. One stakeholder opined that they are
unsure whether regulat or should state such requirement. They suggested that DPO should negotiate the
numbers with the DRM vendor.
Analysis:
160. Enforcing this condition may increase the cost of investment especially for the small DPOs.  Therefore,
Authority is of the view that this  decision should be left to the service provider. Accordingly, the clause Table
2 (18) has been deleted.
Table 2 (19)  of CP
161. In the CP, the following was mentioned:
“DRM should support encryption of individual tracks of a content stream with individual keys , i.e., track level
protection.”
162. In response, one stakeholder suggested that DRM should support encryption of individual channels with
individual keys and encrypt all the content available in the channel. Another stakeholder suggested that DRM
should suppo rt encryption of individual services including all the pids comprising of that service with
individual key for each service. A few stakeholders and an association opined that DRM would encrypt the
complete URL.  It‘s not same as scrambling to identify the video and audio track.
Analysis:
163. After due consideration, the Authority has made amendment to the Regulation.
Table 2 (21)  of CP
164. In the CP, the following was mentioned:
“In case DPO has deployed hybrid STBs, DRM shall ensure that the over -the-top (OTT) App  and any browser
does not get access to the linear television channels offered by the DPO from its own system, and similarly,
DRM for IPTV service should not get access to channels delivered through OTT platform. Provided that, all
the mandatory requiremen ts for DRM shall be complied by hybrid STBs.”
165. In response, one association mentioned that the scope of the Draft Fourth Amendment and Draft Schedule -X
should be limited to DRM requirements for IPTV service only. Another stakeholder opined that Hybrid STB
should be defined. They further mentioned that every application should regulate access to its content
independently, so the content decryption keys are only delivered in licenses of the system that delivers the
content.
166. Another stakeholder suggested that i n case DPO has deployed hybrid STBs, DPO Application integrated with
the DRM shall ensure that the over -the-top (OTT) App and any browser does not get access to the linear
television channels offered by the DPO from its own system, and similarly, DPO Appli cation integrated with
DRM for IPTV service should not get access to channels delivered through OTT platform. Provided that, all
the mandatory requirements for DRM shall be complied by hybrid STBs.
167. One stakeholder suggested that Hybrid STB is an STB with a ccess to internet as well as Linear services. DRM
shall ensure that the over -the-top (OTT) App and any browser does not get access to the linear television
channels offered by the DPO from its own system. DRM for IPTV service should not get access to chann els
delivered through OTT platform. Provided that, all the mandatory requirements for DRM shall be complied by
hybrid STBs. DPO is free to integrate the OTT content on the UI along with linear content at his disposal. The
OTT content has to be protected by  OTT vendor by means of DRM and CPE certification.
168. Another organization suggested that in case DPO has deployed hybrid STBs, if the MSO is providing the linear
television channel on IP delivery also either Unicast or Multicast, the DRM shall ensure that al l the mandatory
requirements are compiled by hybrid STBs. DRM shall also ensure that Any browser does not get access to the
linear television channels offered by the DPO. The IPTV channels should be accessible only in the specified
STB and not in any other  handheld device or computer.

Analysis:
169. ITU‘s Recommendation ITU -T J.298 :  Requirements and technical specifications of a cable TV hybrid set -top
box compatible with terrestrial and satellite TV transport defines Hybrid STB as follows:
“hybrid STB : A hyb rid set -top box (STB) is a STB that uses multiple methods of receiving
transmission signals with video and audio content.
NOTE – For the purposes of this Recommendation, the dual streams will be IP based via the Internet protocols
and cable, satellite and  terrestrial television, based on the ITU -T J.83, DVB -S/S2, DVB -T/T2 or ISDB -T/Tb
standards ‖.
170. Though the hybrid STB may use  multiple methods of receiving transmission signals with video and audio
content, however for the purpose of this regulation, the Aut hority is of the view that it is pertinent to ensure
that in a single instance such STB provides only one type of service. Accordingly, modifications have been
made in the Regulation.
Table 2 (22)  of CP
171. In the CP, the following was mentioned:
“There shall not be any active unique subscriber outside the database tables. Further, there shall not be an
option to split DRM database for creation of more than one instance by a DPO or a vendor.”
172. In response, one stakeholder mentioned that they are not sure if it's  a relevant requirement.
Table 2 (24)  of CP
173. In the CP, the following was mentioned:
“It shall be mandatory to have backup servers and logs of all activities carried out in main server shall be
concurrently copied into the backup servers:
Provided that a lo g of all such instances shall be maintained along with date and time stamp, where the backup
server has been used as the main server:
Provided further that the main and backup server shall always be in sync with regard all data, such as
subscription data, STB UA/MAC ID details, entitlement level information, etc.”
174. In response, one stakeholder mentioned that they appreciate the efforts to have better QoS for the users and it is
in the right direction. However, this should be enforced on other types of DPO si nce majority of the subscribers
are still under the legacy cable TV system or DTH.
Table 2(25)  of CP
175. In the CP, the following was mentioned:
“DRM and SMS shall ensure that the access to database is available to authorized users only, and in “read
only” mod e only. Further, the database audit trail shall be permanently enabled.
Explanation:  Database here refers to the database where data and log of all activities related to STB
activation, deactivation, subscription data, STB UA/MAC ID details, entitlement l evel information, etc., is
being stored.”
176. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/Mac ID‘.
Table 2 (26)  of CP
177. In the CP, the following was mentioned:
“Provision of à -la-carte channels o r bouquet :
(a) DRM (and SMS) shall be able to handle all the channels, made available on a platform, in à la carte mode.
(b) DRM (and SMS) shall have the capability to handle such number of broadcaster/DPO bouquets, as required
by the DPO.”
178. In response , one stakeholder opined that bouquet is irrelevant for DRM system.
Table 2 (28)  of CP
179. In the CP, the following was mentioned:
“DRM shall have a provision to export the database/report for reconciliation with the SMS database. Further,
there shall be a pro vision of reconciliation through secure APIs/secure scripts.”

180. In response, one stakeholder opined that pure DRM may be just a slave of SMS and may not have any DB at
all.
Table 2 (29)  of CP
181. In the CP, the following was mentioned:
“DRM should have the follo wing features:
(a) The entitlement end date in DRM shall be equal to the entitlement end date in SMS,
(b) The entitlement end date in DRM shall be open and SMS shall manage entitlements based on the billing
cycles and payments.”
182. In response, one stakeholder opin ed that DRM should have the following features: (a) The entitlement end date
in DRM shall be equal to the entitlement end date in SMS.  Another stakeholder opined that DRM should have
the following features: (b) The entitlement end date in DRM shall be ope n and SMS shall manage entitlements
based on the billing cycles and payments.
Analysis:
183. After due consideration, the Authority has made amendment to the Regulation.
Table 2(30)  of CP
184. In the CP, the following was mentioned:
“There shall be unique license k ey required for viewing every 10 minutes in DRM deployed by DPO.”
185. In response, one stakeholder suggested that there shall be unique license key required for viewing, the crypto
period should be configurable to change at periodic interval in DRM deployed by  DPO. Another stakeholder
enquired if it is about the key rotation or license renewal period. They further opined that if it‘s the former, this
is probably not feasible in the current systems in the industry. The latter is possible but in big deployments
creates a lot of traffic between the clients and the HE.
Analysis:
186. The Authority is of the view that the unique license key should be a configurable parameter as per the DPO‘s
business model. Accordingly, modifications have been made in the Regulation.
Table 2(31)  of CP
187. In the CP, the following was mentioned:
“For every change in channels, fresh license keys should be issued by the DRM. License keys issued by DRM
should be secure and encrypted. DRM must ensure that the authorization keys are not received by  the STB
from any other source other than the one specified by the IPTV system.”
188. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘. Another stakeholder suggested that that for every change in  channels, fresh license keys should be
issued by the DRM however the various packages can be created with bouquet of channels with same key.
License keys issued by DRM should be secure and encrypted. DRM must ensure that the authorization keys are
not rec eived by the STB from any other source other than the one specified by the IPTV system.
Table 2 (33) of CP
189. In the CP, the following was mentioned:
“IPTV transmission has to be in multicast mode only just like cable TV transmission. There cannot be any such
case where unicast is allowed. STBs with facilities for recording programs shall have a copy protection system
(i.e., a feature which prevents reproduction of content and/or unauthorized copying and distribution of content)
and such recorded content shoul d not be transferrable to any other device.”
190. In response, a few stakeholders and an association suggested that IPTV Transmission shall be agnostic to any
network topology for both Multicast & Unicast methods provided it complies with all regulatory require ments.
STBs with facilities for recording programs shall have a copy protection system (i.e., a feature which prevents
reproduction of content and/or unauthorized copying and distribution of content) and such recorded content
should not be transferrable to  any other device.
191. Another stakeholder suggested that IPTV transmission should be in a closed network circuit just like cable TV
transmission. STBs with facilities for recording programs shall have a copy protection system (i.e., a feature
which prevents r eproduction of content and/or unauthorized copying and distribution of content) and such
recorded content should not be transferable to any other device.

192. A few stakeholders and an association suggested that IPTV transmission can be in both multicast and un icast
encrypted way. STBs with facilities for recording programs shall have a copy protection system (i.e., a feature
which prevents reproduction of content and/or unauthorized copying and distribution of content) and such
recorded content should not be tr ansferrable to any other device.
193. Another stakeholder suggested that IPTV transmission has to be in Local Network only and the IPTV streams
should use only Private IP Address space as per Internet Assigned Numbers Authority (IANA). STBs with
facilities for  recording programs shall have a copy protection system (i.e. the recorded content should be
encrypted with the same DRM and decryption should be allowed only during the subscription period of the
subscriber for that content) and such recorded content shou ld not be transferrable to any other device.
194. One stakeholder suggested that IPTV transmission is to be restricted to the private network of the DPO/LCO in
either multicast/unicast format, IPTV should not be available/transmitted over the Internet. In case  of unicast
delivery the DPO has to use HTTPS along with TLS for secure point to point delivery of the content stream.
The DPO can engage with Telco's for long distance transmission over a dedicated leased line or through a TLS
encrypted tunnel in case of shared infrastructure. STBs with facilities for recording programs shall have a copy
protection system (i.e., a feature which prevents reproduction of content and/or unauthorized copying and
distribution of content) and such recorded content should not be transferrable to any other device.
195. Two stakeholders opined that IPTV is an operator driven and controlled platform in which the consumer
directly interacts with equipment installed by operator in closed user group. IPTV system delivers digital
television s ervice using Internet Protocol (IP) over various access technologies i.e., broadband connection
based on copper loop, optical fibre, wireless technologies etc.
196. One stakeholder suggested that All broadband distribution networks are unicast only and if unic ast is not
allowed for IPTV we need to build an exclusive network for IPTV and there is no business case to implement.
Another stakeholder opined that a separate IPTV clause is required, it‘s not directly related to DRM.
197. Another stakeholder suggested that IPTV transmission has to be in a controlled network, the DPO can
distribute either in Unicast or multicast mode. STBs with facilities for recording programs shall have a copy
protection system (i.e., a feature which prevents reproduction of content and/or unauthorized copying and
distribution of content) and such recorded content should not be transferrable to any other device,
198. An association opined that Unicast is the basic feature of IPTV technology. Any restriction of IPTV to provide
only multicast will reduce the IPTV service to cable services. Further, both GoI and TRAI has always provided
for an enabling and technology neutral regime, therefore, no artificial restriction should be imposed on IPTV
services. Such restriction, if imposed, will disable the  IPTV providers to provide the best of the class services
to consumers. Unicast as a technology is fully compliant with the extant legal and regulatory framework and is
in the larger interests of end consumers without compromising with the rights and privi leges of any other
stakeholder in the IPTV value chain. Legal and regulatory framework in India is technology agnostic.
199. Another stakeholder opined that Multicast is a better way for live streams to be transmitted through IPTV on
wired line network. All acr oss the world, Multicast on IPTV has been working from more than a decade
especially for pay channels and that too with high usage channels. Unicast IPTV is better for small -scale
deployments, while Multicast IPTV is better for large -scale deployments with  a high number of viewers.
However, implementing Multicast requires specialized network hardware and software, which can be expensive
and complicated.
200. An association opined that since Unicast mode allows IPTV services to touch open internet, it cannot be
introduced for the IPTV service DRM, as it will enable the DPO to easily shift the unicast stream from closed
network to open network, which has different jurisdiction and further is the cause of rampant piracy.
Retransmission of linear TV channels envisage d under TRAI regulations is by way of ―broadcast‖ only.
Retransmission of TV channels in Multi cast mode within closed network meets the requirement of a broadcast.
Only technologies fulfilling this requirement should be permitted as mode of retransmission  for IPTV services.
The mode of retransmission used for provision of IPTV services is to be Multi cast only. Since IPTV is a
Broadcast service it can be deployed by Multi cast only.  If Unicast mode is used for provision of linear TV
channels via IPTV, the n it is technically impossible to differentiate between IPTV and OTT at subscriber‘s end as
using Unicast mode may enable the DPO to easily shift the Unicast stream from closed network to open network.
Regulations cannot permit a back door for the IPTV ser vice to be equated to internet enabled services.
Analysis:
201. The Authority believes that a ―technology neutral‖  approach is one of the best  methods  to foster technology
growth.   Accordingly, the mode of delivery of multi channel television programmes to be u sed may be left to the
service providers to decide based on their business model. However, it is pertinent that the system configuration
should ensure that every television channel is available to every customer on selection to view, irrespective of the

mode of delivery of multi -channel television programmes or the number of viewers seeking such channel at any
point of time. Accordingly, modifications have been made in the Regulation.
Table 2 (34)  of CP
202. In the CP, the following was mentioned:
“IPTV transm ission should not be allowed to configure any content delivery network (CDN) in their system
to deliver linear content to STBs.”
203. In response, a few stakeholders and an association opined that IPTV transmission should be allowed to configure
any content del ivery network (CDN) in their system to deliver linear content to STBs, provided it complies with
all regulatory requirements. Another stakeholder suggested that IPTV transmission may be allowed to use
Content Delivery Network (CDN) only in private network and should not be allowed to use any public content
delivery network (CDN) to deliver linear content to STBs. Another stakeholder suggested that IPTV transmission
should be in encrypted format and only the STB/CPE should be allowed to decrypt as per the su bscription status.
If CDN/Stream Multiplexer/Stream Multiplier is involved, it should not have any facility to decrypt and encrypt
and should distribute the stream in the same format of the source stream in real -time.
204. A stakeholder suggested that only pri vate CDN's can be used by the DPO and no public CDN should be allowed.
Private CDN nodes can only be accessed by the DPO customer base and should not be accessible from any other
network. Another stakeholder opined that CDNs help in overcoming the bandwidt h bottlenecks in the distribution
trunk lines. One stakeholder was of the opinion that a separate IPTV clause is required as this is not directly
related to DRM. Another stakeholder enquired that if CDN is not allowed how the catchup content can be
accesse d? Yet another stakeholder suggested that IPTV transmission can be delivered using any of the
technologies (with or without CDN) based on the convenience of the operator.
205. On the contrary, an association opined that in Multi cast mode, delivery of linear TV  channels through IPTV does
not require Content Delivery Networks (CDNs) however in the event Unicast mode is being used the DPO needs
to configure CDNs to deliver the IPTV services and to manage bandwidth and network traffic. IPTV transmission
should not be allowed to configure any CDN.
Analysis:
206. The Authority is of the view that an enabling and light -touch regulatory regime, which facilitates growth and
technological developments while protecting the consumer‘s interest needs to be promoted. In accordanc e with
the policy of ‗light -touch regulation‘ and ‗technology neutral approach‘, the clause has been deleted in the
Regulation. However, it remains incumbent upon IPTV operator to ensure that sufficient safeguards are built -in to
ensure content security an d avoidance of any possibility of delivery of content beyond the closed IPTV network.
The delivery of IPTV services has to be limited to authorised IPTV STBs or authorised unique subscription
identities within the IPTV network.
Table 2 (35)  of CP
207. In the CP , the following was mentioned:
“IPTV should not be allowed to deliver linear content to any other device except STB which has been
whitelisted in DRM.”
208. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/Mac ID (APP)‘. A stakeholder opined that IPTV should be allowed to deliver linear content to any large
screen devices like smart TVs & STB which has been integrated and declared to be tested with the DRM security.
Two stakeholders suggested that it should be allowed on Android TV to avoid unnecessary burden on subscribers.
Another stakeholder opined that perhaps a separate IPTV clause is required as it is not directly related to DRM.
Table 2 (36)  of CP
209. In the CP, the following was mentioned:
“IPTV sh ould have capability to implement session based/token authentication with token authentication duration
to be controllable to few minutes.”
210. In response, one stakeholder opined that perhaps a separate IPTV clause is required as it is not directly related to
DRM.
Analysis:
211. After due consideration, the Authority has made amendment to the Regulation.
Table 2 (37)  of CP
212. In the CP, the following was mentioned:
“IPTV system should not allow recording of linear channel at headend/network level. It should be allowed  to be
recorded at STB/DVR level only, without there being any option available to transfer such recorded content to
any other device.”

213. In response, a few stakeholders and an association suggested that IPTV system should allow recording of linear
channel a t headend/network level provided Content is DRM protected and only authorized STB should be able to
playback the same in line with broadcasters‘ agreements in this regard. It should also be allowed to record at
STB/DVR level, without there being any option  available to transfer such recorded content to any other device.
214. Another set of a few stakeholders and an association suggested that recording in server side need to be allowed to
provide DVR functions of channels and catchup of channel content. They als o suggested additional amendments
that IPTV system can do server -side recording and the recorded content need to store in encrypted way. And the
content will be accessible and decrypted only with the DPOs STBs/Hybrid STBs/Application (APP). Two
stakeholder s also opined that recording at head end level should be allowed to support catchup -tv & time shift, as
it is good features to promote IPTV. One stakeholder opined that a separate IPTV clause is required as it is not
directly related to DRM.
Analysis:
To align with extant Guidelines and Regulations, the above clause has been removed in the Regulation.
Table 2. (38)  of CP :
215. In the CP, the following was mentioned:
“The DRM should have following policies implemented:
(a) It should restrict user to editing or saving content in part or full.
(b) It should restrict user from sharing or forwarding or mirroring the content from the STB
(c) It should disallow user to take screen shots or screen grabs or screen -recording…...”
216. In response, one stakeholder opined tha t (a)-(c) are a mix of loosely bound requirements: a) second part prevents
PVR b) limits implementation of a home gateway c) DRM can't prevent putting a camera in front of the TV
screen and capture the video.
Analysis:
217. Since recording of linear channel is allowed at STB/unique consumer subscription /DVR level, the Authority is of
the view that in Table 2. (38) (a), the following words may be deleted: “or saving content in part or full”
Table 2 {38(d)}  of CP
218. In the CP, the following was mentioned:
“It should  lock access to authorized STBs only.”
219. In response, one stakeholder suggested that it should lock access to authorized STB and smart TV only. A few
other stakeholders and an association suggested that the word ‗STB‘ should be replaced with ‗STBs/APP‘.
Tabl e 2 {38(e)}  of CP
220. In the CP, the following was mentioned:
“It should have Geo blocking, that enables a broadcaster to determine and instruct the DPO/IPTV service
provider to restrict the broadcast of TV channels in locations.”
221. In response, one stakeholder suggested to remove the Geo Blocking clause. They opined that as per the DAS
license provided by MIB, the DPO is free to provide the services as per the licensed territory. Hence this clause
contradicts the provision.
Analysis:
222. The Authority is of the view  that DRM system should have Geo blocking feature, accordingly modifications have
been made in the Regulation.
Table 2. (39)  of CP
223. In the CP, the following was mentioned:
“The DRM should have the capability of being upgraded over -the-air (OTA) so that the connected STBs always
have the most upgraded version of the DRM.”
224. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘.
Table 2 (40)  of CP
225. In the CP, the following was mentioned:

“The DPO shal l ensure that the DRM is updated/upgraded at regular intervals by installing necessary patches,
error corrections, additions, version releases, etc. so as to ensure protection of channels and content at all
times.”
226. In response, one of the organizations sug gested that the word ‗regular intervals‘ should be replaced with
‗whenever required‘.
Analysis:
227. The Authority agrees with the view that in the above -mentioned clause the words ‗regular intervals‘ needs to be
appropriately amended to ensure that the DRM is kept up to date by the DPO by installing necessary patches,
error corrections, additions, version releases, etc. for protection of channels and content at all times. Accordingly,
modifications have been done in the regulation.
Table 2 (41)  of CP
228. In the CP,  the following was mentioned:
“No such functionality should be added to or removed from the DRM which compromises security of channels.
DPO shall be responsible for encryption of channels’ signals before their transmission through its IPTV platform
using D RM integrated STBs. All costs / expenses (by whatever name called) that are required to be incurred or
become payable for such upgradation and for retransmission and/or delivery/distribution of channels to
subscribers shall be borne solely by such DPO. The  DPO shall employ all reasonable security systems and
procedures to prevent any loss, theft, piracy, un -authorized use, reception or copying of channels or any part
thereof and shall notify broadcasters as soon as practicable after it becomes aware that su ch an event has
occurred.”
229. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STBs/APP‘. One stakeholder opined that this clause is for DPO not DRM.
Analysis:
230. Any piracy or content hacking causes marke t disruption and huge financial loss to the service providers. In
addition, it causes loss of tax revenues for the government. The framework prescribed by the Authority is
expected to reduce piracy and benefit the entire ecosystem. Further, in the Copyrigh t Act appropriate remedies
exists to address piracy related issues.
Table 2 (43)  of CP
231. In the CP, the following was mentioned:
“DPO shall promptly, and at it sole cost and expense, correct any issues with the DRM (such as bugs,
defects, omissions or the l ike) that prevents subscribers from accessing the DRM integrated STBs or
channels through the DRM integrated STBs .”
232. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘. One of the organizatio ns stated that the clause was not clear at all.
Table 2 (44)  of CP
233. In the CP, the following was mentioned:
“DPO shall provide broadcasters with video and audio codecs supported by the DRM integrated STBs. The DPO
shall ensure that no such changes/modificat ions are made to such codecs parameters that will require
broadcasters to incur any expense for delivery of channels / content that are free from viewer discernible
problems (including, without limitation, video with no audio, audio with no video or signif icant signal
distortion.)”
234. In response, one stakeholder opined that it is not related to DRM.
Table 2(45)  of CP
235. In the CP, the following was mentioned:
“DRM should ensure that the integrated STBs are verifiably located within India by reference to internet  protocol
address and service address. Further, the DRM shall not permit delivery to an Internet/mobile device. The DRM
must use industry -standard means (including IP -address look -up technology with screening and blocking of
proxies (including anonymizing and spoofed proxies)) to prevent delivery of channels to IP addresses outside of
India or to proxies.”
236. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘. One stakeholder opined that this re ally limits the operator to deliver content only to STBs. Most of

the operators in the world and in India want their DRM protected content to be delivered to mobile devices as
well. Another stakeholder suggested that DRM should ensure that the integrated S TBs are verifiably located
within India by reference to internet protocol address and service address. The DRM must use industry standard
means (including IP -address look -up technology with screening and blocking of proxies (including anonymizing
and spoof ed proxies)) to prevent delivery of channels to IP addresses outside of India or to proxies. One
stakeholder suggested that DRM should ensure that the integrated STBs and Smart TVs are verifiably located
within India by reference to internet protocol addre ss and service address. The DRM must use industry standard
means (including IP address look -up technology with screening and blocking of proxies (including anonymizing
and spoofed proxies)) to prevent delivery of channels to IP addresses outside of India o r to proxies.
237. An association opined that they do not support the deletion of the underlined words, ―Delivery to an
Internet/mobile device cannot be permitted‖ from the above -mentioned clause.
Analysis:
238. With technological developments content can be viewed using application based services provided such
arrangement meets extant licensing/regulatory framework. Therefore, the Authority is of the view that app based
services, may also be permitted. Soft STBs (App based) may also be used for running IPTV services .  In such
cases, the unique id for each subscriber is required. In all such cases, STB or the CPE should have a unique Mac
id that should be paired or locked with a user account. The Authority is of the view that DRM must ensure and
lock the viewership to  single device by single STB/unique consumer subscription or any device by ensuring MAC
ID based authentication. Accordingly, modifications have been made in the Regulation.
Table 2 (46)  of CP
239. In the CP, the following was mentioned:
“DRM should ensure tha t channels are accessible on integrated STBs of only such subscribers who are then -
current, valid subscribers of the distributor of channels, and such confirmation must take place prior to the DRM
actually delivering (or authorizing the delivery of) channe l to the integrated STBs of such subscribers.”
240. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘. One stakeholder suggested that DRM should ensure that channels are accessible on DRM certif ied
STB and Smart TV of only such subscribers who are then -current, valid subscribers of the distributor of channels.
Authorization to the content access should be implemented at both middleware and DRM levels.
Table 2 (48)  of CP
241. In the CP, the following w as mentioned:
“The DRM shall not allow insertion of any self -promotion and/or any third party and/or paid for advertisements
(including banners and aston bands) before, during or after transmission of linear channels.
242. In response, a few stakeholders and an  association suggested that the DRM may allow insertion of any self -
promotion and/or any third party and/or paid advertisements (including banners and Aston bands) before, during
or after transmission of linear channels subject to requisite agreement with the concerned Broadcasters in this
regard. Another stakeholder suggested that the DRM may be allowed to insert any promotion, advertisement
and/or notifications in a manner that it is not interfering with the playback of the linear channels and the content  is
played with covering any portion of it.
243. Two stakeholders suggested that it should be allowed if there is no objection by channel provider and the operator
takes formal approvals for the same. Advertisement banners or Asto bands should be allowed at so me place
holders in such a manner that will not interrupt or block the content. One stakeholder opined that DRM can't
distinguish between Operator's (DPO's) ads and the ones coming from third party.
Analysis:
244. The Authority is of the view that the broadcast er‘s feed should not be tampered/altered by the Distribution
Platform Operators in any manner. The Distribution Platform Operators are bound under agreements executed
with the broadcasters as per the provisions of Interconnection Regulations 2017 (as amend ed). The DRM should
not have any feature to insert any content (including advertisement, portion, etc) by itself. Accordingly,
modifications have been made in the Regulation.
Table 2 (49)  of CP
245. In the CP, the following was mentioned:
“The DRM shall not per mit subscribers to record and/or store channels/content from channels.”
246. In response, a few stakeholders and an association suggested that the DRM may permit subscribers to record
and/or store channels/content from channels subject to requisite agreement wi th the concerned broadcasters in this

regard. Another set of a few stakeholders and an association suggested to remove the clause. They argued that
already they have recording facility in Cable TV STBs. Recording functionality is allowed.
247. One stakeholder s uggested that IPTV system should not allow recording of linear channel at headend/network
level. It should be allowed to be recorded at STB/DVR level only, without there being any option available to
transfer such recorded content to any other device.
Anal ysis:
248. The clause at Table 2 (49) was a repetition of earlier clause, therefore it has been removed in the Regulation.
Table 2 (51)  of CP
249. In the CP, the following was mentioned:
“The DPO shall not sub -license the DRM and/or any rights granted to the DPO by the broadcaster to any entity
for re -transmission of channels to subscribers.”
250. In response, a few stakeholders and an association suggested that the DPO may sub -license the DRM and/or any
rights granted to the DPO by the broadcaster to any entity for re -transmission of channels to subscribers subject to
requisite agreement with the concerned broadcasters in this regard. Another stakeholder suggested that the DPO
shall not sub -license the DRM and/or any rights granted to the DPO by the broadcaster to any ent ity for
retransmission of channels to subscribers, However the DPO can appoint the Distributors and LCOs to deliver the
channels to the subscribers. One stakeholder commented that this is how the content distribution works in many
cases.
Analysis:
251. After du e consideration, the Authority has made amendment to the Regulation.
Additional Clause
252. One stakeholder suggested two additional clauses: 1) DRM System to be deployed on secured server and 2) OTT
Apps currently transmitting Linear Channels to be verified th eir mode of transmission. As HLS or Dash is not
allowed.
Additional Clause
253. A few stakeholders and an association suggested an additional clause that for all the mandatory requirements of
DRM to be suited for STBs/Hybrid STBs/Application (APP). They furthe r opined that in growing technology,
DPO can provide IPTV in app based with all security needs and without violating any security norms of TRAI.
(F) DRM Requirements in so far as they relate to fingerprinting for IPTV services
Table 3 (1)  of CP
254. In the CP , the following was mentioned:
“The DPO shall ensure that it has systems, processes and controls in place to run fingerprinting  at regular
intervals.”
255. In response, one stakeholder opined that it is not related to DRM, rather to the STB app.
Table 3 (2) of CP
256. In the CP, the following was mentioned:
“The STB should support both visible and covert types of finger printing.”
257. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘. One stakeholder opined  that it is not related to DRM, rather to the STB app.
Table 3 (3) of CP
258. In the CP, the following was mentioned:
“The fingerprinting should not get invalidated by use of any device or software.”
259. In response, one of the organizations opined that it is not r elated to DRM, rather to the STB app.
Table 3 (4)  of CP
260. In the CP, the following was mentioned:
“The fingerprinting should not be removable by pressing any key on the remote of STB.”

261. In response, a few stakeholders and an association suggested that the wor d ‗STB‘ should be replaced with
‗STB/APP‘.
Table 3 (6)  of CP
262. In the CP, the following was mentioned:
“The finger printing should be such that it can identify the unique STB number or the unique VC number or the
MAC ID.”
263. In response, a few MSOs and an assoc iation suggested that the finger printing should be able to give the numbers
of characters as to identify the unique STB and/or the MAC ID of STB/APP. One stakeholder opined that there is
no VC in DRM.
Table 3 (7)  of CP
264. In the CP, the following was mention ed:
“The finger printing should appear on the screens in all scenarios, such as menu, Electronic Programme Guide
(EPG), settings, blank screen, and games etc.”
265. In response, one stakeholder suggested that fingerprinting should appear on the screens in all s cenarios, such as
menu, Electronic Programme Guide (EPG), settings, blank screen and in all screens of the Linear channel
Interface in the case of Hybrid STB.
Table 3 (8)  of CP
266. In the CP, the following was mentioned:
“The location, font color and backgrou nd color of fingerprint should be changeable from head end and should
be random on the viewing device.”
267. In response, one stakeholder suggested that it is for application not DRM.
Table 3 (9)  of CP
268. In the CP, the following was mentioned:
“The finger printi ng should be able to give the numbers of characters as to identify the unique STB and/or the
MAC ID.”
269. In response, a few MSOs and an association suggested adding ‗of STB/APP‘ at the end of above clause.
Table 3 (10)  of CP
270. In the CP, the following was menti oned:
“The finger printing should be possible on global as well as on the individual STB basis.”
271. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Table 3 (13)  of CP
272. In the CP, the following  was mentioned:
“The DRM shall support and enable forensic watermarking at STB level.”
273. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘. Another stakeholder opined that similar security feat ures should also be implemented for other types
of DPOs.
Table 3 (14)  of CP
274. In the CP, the following was mentioned:
“The DRM shall have the capability to run fingerprinting at regular intervals of at least one fingerprinting every
ten (10) minutes on a 24x 7x365 basis) and provide broadcasters with the fingerprint schedule on request.”
275. In response, one stakeholder opined that for anti -piracy, the client may randomize the times of the fingerprinting
on each device, therefore the schedule can't be provided.
Analysis:
276. The Authority is of the view that the DRM should have the capability to run fingerprinting with at least one
fingerprinting every ten (10) minutes on a 24x7x365 basis.  DRM should have a feature to publish report of
fingerprinting schedule for defi ned interval. The DPO shall make such report available to broadcaster on request.

Table 3 (15)  of CP
277. In the CP, the following was mentioned:
“The DRM shall have the capability to run customized fingerprinting at such intervals as may be requested by
broadc asters. Further, DPOs shall mandatorily run fingerprinting at regular intervals with a minimum of 2
fingerprints per hour on a 24x7x365 basis and provide broadcasters with the fingerprint schedule on request.”
278. In response, one stakeholder opined that the c lause is for application not DRM.
Analysis:
279. The clause of Table 3 (15) was a repletion of earlier clause, therefore it has been removed in the Regulation.
(G) DRM Requirements in so far as they relate to STBs
280. In response, a few stakeholders and an associa tion suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘.
Table 4 (1)  of CP
281. In the CP, the following was mentioned:
“All STBs should have a DRM content protection.”
282. In response, a few stakeholders and an association suggested that the word ‗S TBs‘ should be replaced with
‗STBs/APP‘. One stakeholder enquired on which STBs was the above clause applicable.
Table 4 (2)  of CP
283. In the CP, the following was mentioned:
“The STB deployed should be capable to  support content decryption, decoding and DRM l icense evaluation.”
284. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Table 4 (3)  of CP
285. In the CP, the following was mentioned:
“The STB should be capable of displaying fingerprinting insert ed from Headend through DRM/SMS. The STB
should support both targeted channel fingerprinting as well as all global fingerprinting.”
286. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Table 4 (4) of CP
287. In the CP, the following was mentioned:
“The STB should be individually addressable from the Head -end.”
288. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Table 4 (5)  of CP
289. In the C P, the following was mentioned:
“The STB should be able to receive messages from the Head -end.”
290. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘. One stakeholder opined that it is unrelated to DRM.
Table 4 (6)  of CP
291. In the CP, the following was mentioned:
“The messaging character length should be minimal 120 characters.”
292. In response, one stakeholder suggested that messages of length of 1 to 120 or more characters shall be supported.
Analysis:
293. The Authority agrees with the suggestion of the stakeholder that the messaging character length should be
minimal of up to 120 characters. Accordingly, modifications have been made in the Regulation.

Table 4 (7)  of CP
294. In the CP, the following was mention ed:
“There should be provision for global messaging, group messaging and the individual STB messaging.”
295. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Table 4 (9)  of CP
296. In the CP, the fol lowing was mentioned:
“The STBs should be addressable over the air to facilitate OTA software upgrade.”
297. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘.
Table 4 (10)  of CP
298. In the CP, the following was mentioned:
“The STBs with facilities for recording the programs shall have international standard copy protection system.”
299. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘.
Table 4 (11)  of CP
300. In the CP, the following was mentioned:
“The STB should have a provision that fingerprinting  is never disabled.”
301. In response, a few stakeholders and an association suggested that the word ‗STBs‘ should be replaced with
‗STBs/APP‘.
Table 4  (12) of CP
302. In the CP, the following was mentioned:
“The watermarking network logo for all pay channels shall be inserted at encoder end only. In case of
infrastructure sharing, it shall be as per terms and conditions of infrastructure sharing.”
303. In respons e, one association suggested that the words ‗In case of infrastructure sharing, it shall be as per terms
and conditions of infrastructure sharing‘ should be deleted. In support of their argument, they opined that at
present, there are no guidelines issued by MIB regarding infrastructure sharing between IPTV operators, and as
such, there are inter -alia jurisdictional issues concerning infrastructure sharing between IPTV operators. Another
stakeholder suggested that the first line of the clause should read as  follows: The watermarking network logo for
all channels should be inserted at encoder/Transcoder end only.
Table 4 (13)  of CP
304. In the CP, the following was mentioned:
“DRM deployed should be able to send scroll messaging which should be only available in t he lower part of the
screen.”
305. One stakeholder suggested that the word ‗DRM‘ should be replaced with ‗DRM/SMS‘. One stakeholder opined
that it is not related to DRM.
Analysis:
306. It is learnt that SMS can execute the required function without DRM involvement. Accordingly, modifications
have been made in the Regulation.
Table 4 (14)  of CP
307. In the CP, the following was mentioned:
“DRM deployed should be able to geo tag STB deployed in the network for security.”
308. In response, a few stakeholders and an association su ggested that the word ‗STB‘ should be replaced with
‗STB/APP‘. One stakeholder opined that the clause is probably for the application, not DRM.
Table 4 (15)  of CP
309. In the CP, the following was mentioned:

“STB should take all commands directly from DRM not f rom any intermediate servers.”
310. In response, a few MSOs and an association suggested that the word ‗STB‘ should be replaced with ‗STB/APP‘.
Another stakeholder suggested that STB should take all commands directly from SMS/DRM not from any
intermediate serve rs. One stakeholder opined that there are many commands not related to security/DRM that
STB can fetch from other sources.
Table 4 (16)  of CP
311. In the CP, the following was mentioned:
“STB should not have feature to download (direct or side download) any 3rd  party App/APK (Including on
Hybrid STB’s if any) and should not have access to any browser.”
312. In response, a few MSOs and an association suggested that STB may have a feature to download 3rd party
App/APK directly from in -built app store and may also have access to a browser. However, side loading of any
third -party app should not be allowed on the STB. At the same time, STB having an integrated browser to serve
relevant Hybrid STB features, it should not allow any unauthorized access to IPTV through browse r.
313. A few stakeholders and an association suggested that the clause needs to be removed. Another stakeholder opined
that this is a very valid point and the same to be amended for other DPO platforms like DTH Hybrid boxes. Two
stakeholders suggested that ST B should be allowed to download / side load app or apk to install 3rd party apps.
Until unless it is not counterfeiting the copyrights law.
314. Another association suggested that the clause should read as follows:  IPTV STB should not have feature to
download  (direct or side download) any 3rd party App/APK and should not have access to any browser.‖
Analysis:
315. The Authority is of the view that STB/unique consumer subscription while using IPTV infrastructure should not
have feature to download (direct or side do wnload) any 3rd party App/APK  and should not have access to any
browser. Accordingly, modifications have been made in the Regulation.
Table 4 (17)  of CP
316. In the CP, the following was mentioned:
“STB should not be able to access the authorization keys from any other source except from the IPTV system
through the IPTV closed network. DRM must ensure that the authorization keys are not received by the STB from
any other source other than the one specified by the IPTV system.”
317. In response, one stakeholder enqui red about the meaning of authorization keys.
Table 4 (18)  of CP
318. In the CP, the following was mentioned:
“STB should not have any play store to download 3rd party App.”
319. In response, a few stakeholders and an association suggested that STB may have a feature  to download 3rd party
App/APK directly from in -built app store and may also have access to a browser. However, side loading of any
third -party app should not be allowed on the STB. At the same time, STB having an integrated browser to serve
relevant Hybri d STB features, it should not allow any unauthorized access to IPTV through browser.
320. Another association suggested that the clause should read as follows: IPTV STB should not have any play store to
download 3rd party App.
321. A few stakeholders and an associ ation suggested that the clause needs to be removed. A few stakeholders
suggested that STB can have Play store / app store to download 3rd party app. Another organization opined that it
is not what modern STBs and operators offer. There can be an App Store  with a limited set of allowed apps.
Another MSO suggested that the same should be amended for other DPO platforms like DTH Hybrid boxes.
Analysis:
322. The Authority is of the view that no play store should be accessible for enabling download, etc. when STB/un ique
consumer subscription, is functioning in the IPTV network.
Table 4 (19)  of CP
323. In the CP, the following was mentioned:
“STB should have copy protection – HDCP with version 2 and above, DHCP, CGMS & macrovision with version
7 and above.”

324. In response, a few stakeholders and an association opined that Schedule III regulations can be followed which is
more than enough for content security. Another stakeholder opined that the point lacks merit. They mentioned
that majority of the cable TV viewers are having legacy TVs. It is very unlikely that the mentioned protocols
would be supported by these legacy TVs and other devices. Another stakeholder suggested that STB should have
copy protection – HDCP with version 2.
Analysis:
325. The Authority is of the view that th e Regulation should specify STB /unique consumer subscription should have
copy protection and the means of achieving the same should be left to the service providers.
Table 4 (20)  of CP
326. In the CP, the following was mentioned:
“DPO system should have capabil ity to maintain un -editable logs of all activity and configurations including
download of any App at STB end.”
327. In response, a few stakeholders and an association opined that with all these content protection and anti -piracy
systems which are requested by T RAI and broadcaster can be met out by the DPOs DRM, SMS and STBS/APP.
There is no compromise in security. So, restricting internet and OTT for anti -piracy is baseless. Another MSO
opined to amend for other DPO platforms like DTH hybrid boxes.
Analysis:
328. The Authority is of the view that DPO system should have capability to maintain un -editable logs of all activity
and configurations including download or upgrade of IPTV services App (if any) at STB/unique consumer
subscription end. Accordingly, modifications  have been made in the regulation.
Table 4 (21)  of CP
329. In the CP, the following was mentioned:
“The DRM should not allow delivering linear TV channels on HLS, Smooth Streaming, Dash & HTTP/TCP.”
330. In response, a few stakeholders and an association suggested t hat the DRM may allow delivering linear TV
channels on HLS, Smooth Streaming, Dash & HTTP/TCP subject to IPTV service being not accessible on Open
Internet, i.e., IPTV Service should strictly be accessible in a managed network with DRM protection.
331. Another  set of a few stakeholders and an association opined that IPTV transmission via multicast will not prevent
content theft and piracy. With TCP HTTP even a better security can be provided and Quality of service can be
improved as it has feedback for every si ngle session of customer. And even in case of hacking it can be easily
identified with feedback from session.
332. Another stakeholder suggested that the DRM should allow delivering linear TV channels to any protocols as
desired by DPO. Another stakeholder sugg ested that only the DRM supported streaming containers/formats
(MPEG -TS, MpegDash, hls etc) and network protocols (http, hls, TCP, UDP etc) should be deployed. Two
stakeholders suggested that DRM may allow delivering linear TV channels in any mode enabling  content
protection to avoid piracy. One stakeholder opined that it's about blocking OTT, which contradicts the common
modern trend.
Analysis:
333. The Authority is of the view that the DRM should not allow delivering linear TV channels on Internet. The
deliver y of multi channel television programmes  should remain in a closed network within the device.
Accordingly, modifications have been made in the regulation.
Table 4 (22)  of CP
334. In the CP, the following was mentioned:
“The STB should have forced messaging capa bility including forced finger printing display.”
335. In response, a few stakeholders and an association suggested that the word ‗STB‘ should be replaced with
‗STB/APP‘.
Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi -110064
and Published by the Controller of Publications, Delhi -110054.

                

                
                
                
            

            
        


        
        

        
        
        

            

                

                    
                        
                    
                

                

                    
Never miss important gazettes

                    
Create a free account to save gazettes, add notes, and get email alerts for keywords you care about.

                

                Sign Up Free
            

        

        

        
        

        
        
        

            Create free account to save & get alerts →
        

        

        
        
        

            

                
                    
                    
                
                More from Telecom Regulatory Authority of India
            

            

                
                

                    
                        In exercise of the powers conferred by section 36, read with sub clauses (i) and (v) of clause (b), clause (c) and clause (d) of subsection (1) of section 11, of the Telecom Regulatory Authority of India Act, 1997
                    
                    22 May 2026
                

                
                

                    
                        In exercise of the powers conferred by section 36, read with sub clause (i) of clause (b) of sub section (1), of section 11 of the Telecom Regulatory Authority of India Act
                    
                    27 Mar 2026
                

                
                

                    
                        In exercise of the powers conferred upon it under sub section (2) of section 11, read with sub clause (i) of clause (b) of sub section
                    
                    27 Mar 2026
                

                
                

                    
                        In exercise of the powers conferred by section 36, read with sub clauses ii, iii and iv of clause b of sub section 1 of section 11, of the Telecom Regulatory Authority
                    
                    05 Feb 2026
                

                
                

                    
                        In exercise of the powers conferred upon it under sub section 2 of section 11, read with sub clause  i of clause b of sub section
                    
                    17 Jun 2025
                

                
                

                    
                        In exercise of the powers conferred upon it by section 36, read with sub clause v of clause b and clause c of sub section 1 of section 11, of the Telecom Regulatory Authority of India Act
                    
                    18 Feb 2025
                

                
                

                    
                        In exercise of the powers conferred upon it under section 36, read with sub clauses (i) and (v) of clause (b) of sub section (1) of section 11, of the Telecom Regulatory Authority of India Act
                    
                    30 Dec 2024
                

                
                

                    
                        In exercise of the powers conferred upon it under sub section (2) of section 11, read with sub clause (i) of clause (b) of sub section (1) of the said section, of the Telecom Regulatory Authority of India Act
                    
                    30 Dec 2024
                

                
            

            

                View all Telecom Regulatory Authority of India gazettes →