NEW DELHI – Telecom regulator TRAI on Monday issued draft amendments to its broadcasting and cable interconnection rules, seeking comments from stakeholders on new audit procedures and provisions for infrastructure sharing.
The Telecom Regulatory Authority of India released the draft Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Seventh Amendment) Regulations, 2025. If adopted, the changes will come into force on April 1, 2026.
The amendments are designed to address long-standing concerns over the accuracy of subscriber reporting and the cost of compliance for smaller operators. They follow a consultation paper issued in August 2024 on audit provisions and the audit manual, which drew a wide range of responses from distributors, broadcasters and industry associations.
Shift to financial year audits
TRAI said the annual audit of subscriber management and conditional access systems will be aligned to the financial year, from April to March, instead of the calendar year. Distributors of television channels must complete audits for the preceding financial year and share reports with broadcasters by September 30 each year.
The regulator said this would bring audits in line with financial reporting and contractual cycles already used by service providers, reducing administrative burdens and improving consistency.
Audits must be conducted by Broadcast Engineering Consultants India Limited (BECIL) or auditors empanelled by TRAI. Distributors must inform broadcasters 30 days in advance of the audit schedule and the name of the auditor. Broadcasters may depute a representative to attend the audit and provide inputs.
Distributors with fewer than 30,000 active subscribers at the end of the previous financial year will not be required to undergo mandatory annual audits. TRAI said the exemption was aimed at easing the financial and operational burden on small operators, many of whom had argued that audit costs consumed a disproportionate share of their revenues.
Broadcasters will, however, retain the right to commission audits at their own expense if distributors in this category fail to provide reports.
Dispute resolution and compliance
If a broadcaster finds discrepancies in an audit report received by the deadline, it may raise objections with supporting evidence within 30 days. The auditor will be required to address these concerns and provide an updated report within another 30 days. If the broadcaster remains dissatisfied, it can escalate the matter to TRAI, which may allow a special audit at the broadcaster’s cost.
Where audits reveal discrepancies in subscriber numbers, settlements will be handled under interconnection agreements. If systems fail to meet technical requirements, broadcasters may disconnect signals after giving three weeks’ notice.
In cases where distributors do not provide audit reports by September 30, broadcasters may either jointly or individually commission audits, to be completed within four months.
The draft regulations also include provisions to address infrastructure sharing, following guidelines issued by the Ministry of Information and Broadcasting. Distributors that share subscriber management or conditional access systems must ensure separate instances for each entity and maintain segregated data.
On watermarking, the rules propose that network logos for all pay channels should be inserted at the encoder level by infrastructure providers, while logos of last-mile distributors may be inserted through set-top boxes or middleware.
Divergent stakeholder views
The consultation process revealed sharp differences within the industry. Several stakeholders supported retaining mandatory annual audits, arguing they are necessary to curb under-reporting and ensure transparency. Others called for audits to be required only once every two or three years, citing cost and administrative burden.
Some industry groups opposed any exemptions for smaller operators, saying they could lead to revenue leakage, piracy and uneven enforcement. Others backed exemptions for distributors below certain subscriber thresholds, ranging from 5,000 to 50,000.
Broadcasters expressed concerns that distributors often delayed audits or submitted incomplete reports, limiting their ability to verify subscriber numbers. Distributors, on the other hand, said repeated audits requested by broadcasters added unnecessary costs and complexity.
TRAI said written comments on the draft regulations should be submitted by October 6, 2025.
The proposed changes mark the seventh amendment to the 2017 Interconnection Regulations, which have been revised several times in response to evolving industry practices and disputes.
