Guidelines on implementation of Quality of Service (Code of Practice for Metering and Billing regulation Accuracy) Regulations 2023

F. No. C-2/8/(1)/2021-QoS Dated: 19-09-2023

To

a. All Unified Access Service Licensees b. All Unified Licensee(s) with Authorization for Access Service c. All empaneled auditors to audit the accuracy of metering and billing systems of the service providers

Subject: Implementation of Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023 (03 of 2023) dated 11.09.2023 – Guidelines thereof.

TRAI has issued Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023 (03 of 2023) on 11.09.2023, repealing the extant regulation the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2006 (05 of 2006). These regulations shall come into force from 01st day of April 2024.

2. In this regard, attention of the addressee, is invited to the Sub regulation (6) of regulation 5 of Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023 (03 of 2023) which provides that, “Every service provider shall adhere to such guidelines and checklist for the audit, as may be issued by the Authority in this regard, from time to time”.

3. In accordance with the provisions contained in the sub regulation (6) of regulation 5 of Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023 (03 of 2023) dated 11.09.2023, the Authority issues herewith the guidelines for the audit of metering and billing systems of the service providers, enclosed as Annexure-A.

4. All Unified Access Service Licensees, Unified Licensee(s) with Authorization for Access Service including the auditors empaneled to conduct audit under these regulations, shall undertake the audit of metering and billing systems of the service providers in accordance with these guidelines.

Enclosure: Annexure-A

(Tejpal Singh) Advisor (QoS-I)

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Annexure ‘A’

Guidelines for Audit of the Metering and Billing System under Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023

1 Introduction The audit, under Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023, shall be conducted for accuracy of metering and billing system(s) whether centralized or distributed, herein after called as Metering and Billing System, as well as records pertaining to billing including subscribed tariffs on offer and billing complaints as per these regulations.

2 Empanelment of Auditors: TRAI shall empanel auditors for conducting audit as per the provisions of the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023.

3 Obligations of the Service Providers Every service provider shall

3.1 get its Metering and Billing System(s) and Licensed Service Areas, audited for access service by an auditor, appointed in accordance with the said regulations in such a manner that –

(i) the audit of the accuracy of each Billing System, whether centralized or distributed, at different locations/zones, is to be done before taking up the audit of any Licensed Service Area being served by that Billing System;

(ii) each Billing System is audited at least once in a financial year latest by 30th June of the financial year;

(iii) each Licensed Service Area is audited for accuracy of metering and billing at least once in a financial year;

(iv) the Licensed Service Areas, for the purposes of audit, are evenly distributed throughout the four quarters of a financial year as far as possible and in every quarter of a financial year, at least one Licensed Service Area is audited.

3.2 submit to the Authority, by the fifteenth day of April of the financial year, its annual schedule of audit, containing the details of Billing Systems and Licensed Service Areas scheduled to be audited.

3.3 ensure that the audit shall be conducted in accordance with the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023 and the guidelines/ checklist issued by the Authority from time to time.

3.4 submit the details of data related to billing complaints, all outstanding amounts, to be refunded to the subscribers, at the beginning of the financial year for all LSAs to the Authority and the auditors.

3.5 provide to the auditor, within thirty days of receipt of request, the raw call data records pertaining to service usage.

3.6 provide to the auditor, within seven days of receipt of request, the addresses of the metering and billing systems with details of LSAs being served by it, and LSA(s) offered for audit with contact details of the nodal officers in charge for the audit and other relevant documents as may be required by the auditor, for the conduct of audit.

3.7 ensure that empaneled auditors are facilitated in the smooth conduct of audit.

3.8 provide access to the Metering and Billing System or any other node(s) relevant for the purpose for audit and documents upon request from the auditors.

3.9 provide to the auditors, written comments or clarifications with necessary documents and/or system-generated records on every audit observations, in the given time frame. The detailed comments shall inter-alia include-

(i) reasons for occurrence of the problem; (ii) date of occurrence of the problem; and (iii) date of rectification of the problem.

3.10 submit the audit report to the Authority as per the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023.

3.11 submit the action taken report to the Authority as per the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023, on each audit observation containing therein the details of the action taken on audit observations, and such details shall include-

(i) reasons for occurrence of the problem; (ii) date of occurrence of the problem; (iii) date of rectification of the problem; (iv) action taken to address the problem; (v) number of subscribers affected and the total overcharged amount involved; (vi) number of such subscribers to whom refunds were made within time limit specified in the regulation and the total amount so refunded; and (vii) the number of the subscribers to whom refunds could not be made and total amount which could not be refunded; (viii) the number of the subscribers to whom refunds were made after the specified time limit and total amount so refunded; (ix) status of audit observations pending to be resolved from previous audits, in such format as the Authority may prescribe from time to time.

4 Guidelines for Auditors

4.1 The auditors shall undertake audit of the Billing system(s) of service provider before taking up the audit of the LSAs. The audit of LSAs shall be done only after completion of audit of its Billing System.

4.2 Based on Audit methodology, LSA audit activities may have two components i.e. (a) activities which may be conducted centrally after or along with the system audit of Billing System and (b) activities which require onsite visits to LSAs based on service providers’ network topology and operational setup. The Auditors may consider this aspect in overall audit activities schedule and communicate the same to the service providers clearly. The audit activities which can be conducted centrally for the LSAs should not be repeated in those LSAs.

5 Auditors’ Obligations:

5.1 The auditor shall undertake audit of the Metering and Billing System of service provider and certify that service providers’ Metering and Billing System is in compliance with the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023 and guidelines/ direction(s) issued by the Authority from time to time. The auditor shall further take up audit of accuracy of metering and billing in License Service Area (LSA) as per the prescribed Audit Methodology.

5.2 The auditors shall strictly adhere to the schedule of audit as specified in the regulations and intimate to TRAI, before it begins the audit.

5.3 The auditor shall preferably have team of domain experts and tools to conduct the audit as per regulations. However, if required, the auditors may associate revenue assurance experts/ solutions in their audit work. However, such experts should not be associated with revenue assurance solutions of concerned service provider. TRAI shall be intimated forthwith the details of such arrangement if any, with revenue assurance experts with their current associations with service provider.

5.4 The auditors shall maintain confidentiality of information/data shared by service providers for conduct of audit and may need to sign a non-disclosure agreement with service providers, if required.

5.5 The auditors shall comply with all the regulations, directions, instructions, guidelines etc. issued by TRAI from time to time for the purpose of conducting the audit and reporting thereof.

5.6 The auditors shall not undertake audit of the metering and billing system of any service provider to whom the auditor is or has been statutory auditor, cost auditor or internal auditor for last two financial year (from the year prior to the audit year) or has any conflict of interest in fair conduct of audit.

5.7 The auditors shall promptly report to the Authority any critical matters/ observations noticed/ noted while conducting audit of metering and billing system of any service provider.

5.8 The Authority may refer complaints relating to metering, billing, value added services etc. for verification and inclusion of the findings in the audit report.

5.9 The auditors may be asked to give detailed presentation covering key findings of audit including the process/procedure adopted for the audit. The auditor shall attend such meetings/ presentations at their own expenses.

5.10 The auditors shall expeditiously submit a copy of the report(s) to the authority on completion of the audit.

5.11 The auditors shall securely maintain all records of audit of respective financial year, including the data shared by the service providers, for minimum next two financial years and submit to the Authority, if asked for.

If an auditor fails to comply with the provisions of these regulations and direction or guidelines issued from time to time, the auditor shall be liable to be removed from the panel of the auditors; Provided that reasonable opportunity shall be given to the auditor before removal from panel.

6 Audit Methodology The auditors shall follow the audit methodology provided in Appendix-I of these guidelines for conduct of the audit.

7 Submission of Audit Report

7.1 The auditors shall prepare the audit report for the Billing System(s) as well as LSAs audited for the quarter, expeditiously in the format prescribed by the Authority as per the specified schedule.

7.2 The auditors shall not delay the preparation of the audit report, waiting for the comments of the service provider on any audit observation.

7.3 After completion of audit of the Billing System(s) or LSA, as the case may be, the auditors shall submit a copy of audit report and key findings of the audit to TRAI as per the schedule.

7.4 The areas of concern identified during audit shall be categorized into three categories as described below:

(i) Category 1 (Non-Compliance): An important matter of non-compliance or deficiency for which corrective action must be undertaken urgently. In view of the grave consequences of a Category 1 matter, it is expected that a service provider shall resolve it as a matter of utmost importance. In any event a detailed corrective action plan must be agreed within one month and put into effect immediately and details thereof be included in audit report.

(ii) Category 2 (Deficiency): A matter of concern, which is to be resolved within a period, agreed with the auditor. In any event a detailed corrective action plan must be agreed and put into effect within three-months and details thereof be included in audit report.

(iii) Category 3 (Observations): A matter worthy of consideration by the service provider, possibly leading to corrective and/ or preventative action, but not of sufficient importance to warrant Category 1 or 2 status.

7.5 The audit report shall, inter-alia, cover following details:

(i) Brief overview of Metering and Billing System or LSA as applicable (ii) Key findings or observations (iii) Analysis and conclusion of billing complaints of the subscribers under broad categories (iv) Instances of overcharging, service provider’s comments and final remarks of the auditor in such format and at such intervals as the Authority may prescribe, from time to time. (v) Action taken by the service provider on the overcharging and verification thereof including his opinion with reasons thereto. (vi) Comments of the service provider against each audit observation and auditor’s opinion on these comments. (vii) Non-acceptance of audit observation by the service provider, if any, along with service provider’s comments thereon. (viii) Observation on compliance to the code of practice by service provider for metering and billing accuracy laid down in the regulations. (ix) Other relevant details as specified by Authority time to time.

8 Miscellaneous During the audit, TRAI may entrust the auditor to undertake special audit on any issue. The auditor shall undertake an audit on such issue and shall report to TRAI about the findings of such audit in such format and in such time frame as specified by TRAI in this regard.

9 Timeline for Audits and submission of reports

*Action taken report shall also include the status of all pending audit observations of previous quarters, if any.

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Appendix-I Audit Methodology

1 The Auditors shall undertake the audit of metering and billing system(s) of the service providers, both for prepaid and postpaid subscribers of access service provided on wire line and wireless media, in accordance with the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023 and the guidelines/ directions issued by the Authority from time to time.

2 The auditor shall evaluate, inter alia, the correctness of the following during the audit:

2.1 The generation process and accuracy of the Call Data Records (CDR) by the nodes responsible for metering, billing and applications of policy rules, if any. 2.2 The software logic and configuration log report of the IT nodes and systems deployed by service providers for testing the configuration of tariff plans and all kinds of vouchers before launch, encompassing all use case scenarios of the application of different tariff plans and vouchers subscribed. 2.3 The correctness of CDR vis-à-vis the rate applied, duration mentioned, origination and destination codes. 2.4 Compliance with the relevant Regulations, Telecom Tariff Orders, Directions, orders, and instructions issued by Authority as amended from time to time. The current list of the same, as on date, is available in Annexure II which may be amended in future. 2.5 The auditor is free to use and verify the correctness of configuration check mechanism of the tariff of the service providers, using their own tools and testing software.

3 Pre-Audit Activities: The Auditors shall

3.1 familiarize with the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation, 2023, associated guidelines/ instructions/ directions and various tariff orders, directions and other regulations issued by the Authority from time to time. 3.2 obtain the details of Nodal Officer(s) of service provider who are authorized for coordinating the audit activities, furnishing of records and reply to the audit observations. 3.3 obtain list of each metering and billing system(s) and policy/rules configurations system, along with details of its location, LSAs served and other relevant details required for smooth conduct of audit. 3.4 collect the details of billing complaints, outstanding amount, to be refunded to the subscribers, from the service provider and verify the same or any other relevant details for conduct of audit.

4 Audit of Centralized/Distributed Billing System

4.1 The service provider shall ensure that audit of its billing or charging system, either centralized or distributed at different locations, is done before taking up audit of any license service area being served by that billing or charging system. 4.2 To ascertain the accuracy of billing system(s), auditor shall conduct audit of various processes and configurations defined in centralized and/or distributed billing system(s) of the service providers before taking up LSA wise audit. While auditing billing system(s) auditor shall check following broad processes with relevant logs or system generated reports, not limited to the listed below:

(i) flow of CDR/ IPDR from CDR/IPDR generating nodes to central billing system and their processing in mediation or charging system (ii) rating methodologies defined in billing systems to rate CDRs for billing of post-paid subscribers or apply online charging for prepaid subscribers (iii) policy definitions if any, done for fair use or any other policies as applicable to the tariff offering including their impact on rating processes for post-paid and pre-paid subscribers. (iv) billing methodologies for Value Added Services and their rating or charging in the system for post-paid and pre-paid subscribers (v) configuration, processing, and application of online charging for pre-paid System for various kinds of usage by the subscribers (vi) applicability of tariff offering through e-charging/portal charging /app based and/or physical charging systems to the subscriber’s account (vii) applicability of credit mechanism, if any, applied to subscribers through third party offering (viii) subscriber’s balance management including grace periods management, if any applicable (ix) top-up and carry forward mechanism for tariff offering allowing auto refilling of subscriber’s account after predefined intervals (Ex- daily 1GB usage or 100 minutes calls or 100 SMSs etc.) (x) any other offers not listed above but applicable to the subscribers

5 Audit of the LSAs

5.1 STEP-1 Audit of Metering System

5.1.1 The auditor shall check metering and mediation process by making sample test calls to ascertain that metering and mediation process is accurate and no systematic deficiency noticed. 5.1.2 Accuracy of measurement of metering shall be checked by simulating conditions of various services being rendered such as making test voice calls, sending messages, and establishing data sessions, provisioning VAS service etc., using test numbers. Such verification shall be done in at least five network elements/ nodes of the LSA, generating CDR/ IPDR and also responsible for policy definitions (like fair usage applications, daily data volume limits etc.). These network elements/ nodes should be distinct and geographically spread across the LSA. Preference should be given to newly commissioned network elements/ nodes. The testing/ verification shall be done by making at least ten test calls per network element/ node covering various services viz. voice calls/ messages/ data sessions, VAS services etc., as applicable. 5.1.3 The auditor shall compare the duration/ count/ time/ volume of data of test voice calls/messages/ data sessions/ VAS recorded in the raw CDRs/ IPDRs with the corresponding values measured by the software or equipment, used for making such test voice calls/ messages/ data sessions/ VAS, using standard/ established techniques. 5.1.4 The accuracy of measurements should be within the limit prescribed in the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulation 2023. The findings shall be recorded in the audit report along with the details of the test voice calls/ messages/ data session made. 5.1.5 The service provider shall submit the details of updated outstanding amount, to be refunded to the subscribers, at the end of quarter for the LSAs being audited, to the auditor. The auditor shall verify the same during the audit.

5.2 STEP-2- Tabulation of Tariff offerings

5.2.1 The auditor shall obtain the details of all the tariff offerings (excluding Service Level Agreement based tariff offerings) viz. tariff plans, Plan Vouchers, Special Tariff Vouchers (STVs), Combo Vouchers (CVs), Top Up Vouchers (TUVs), Add-on plans offered to prepaid and postpaid subscribers of access service provided on wireline and wireless media, as per the format prescribed in Annexure- I-A to I-D, whichever is applicable, from the service provider. 5.2.2 The service provider shall provide the information as per the tariff configured in the system. A certificate stating that there is no discrepancy in the information provided in Annexure- I-A to I-D and that configured in the system for metering and billing of/to the subscribers, shall be submitted by the service provider to the auditor. 5.2.3 Details of all such tariff offerings, fulfilling one or more criteria, as mentioned below, shall be included in the Annexure- I-A to I-D:

(i) available for subscription as on last day of the quarter for which audit is being done; (ii) having at least one active subscriber at the beginning of the quarter for which audit is being done; (iii) having at least one active subscriber at the end of the quarter for which audit is being done; (iv) subscribed by at least one subscriber during the quarter for which audit is being done;

5.2.4 The auditor shall also prepare separate Annexure- I-AA to I-DA, similar to Annexure- I-A to I-D, for all the tariff offerings based on the information filed with TRAI by the service provider. 5.2.5 The auditor shall verify the details of all tariff offerings configured in the systems and provided by the service provider in Annexure- I-A to I-D with the details of tariff offerings prepared by the auditor in Annexure- I-AA to I-DA. Any inconsistency including missing information shall immediately be brought to the notice of the service provider for taking necessary corrective action, under intimation to TRAI. Such findings shall be recorded in the audit report.

5.3 STEP-3- Categorization and grouping of Tariff offerings for Audit

5.3.1 The service provider shall also categorise all tariff offerings, while submitting the details to the auditor in Annexure- I-A to I-D, under various groups after analysing the likely impact of the tariff offering on various service components viz. call, data, message, ISD call rate, call rate in international roaming, monetary value, validity, value added services etc. 5.3.2 The groups so formed shall be the broad categories from which representative sample of tariff offerings are to be selected for audit. An indicative list of various groups is as follows:

Note: The list is an indicative only and not exhaustive. More groups can be formed based on tariff offerings of the respective service provider.

5.3.3 All the tariff offerings in each annexure, are to be clubbed in groups irrespective of whether it is a tariff plan, plan voucher, special tariff voucher (STV), combo voucher (CV), top up vouchers (TUV), add-on plan etc. 5.3.4 From each group of each annexure, five most popular tariff offerings or all tariff offerings under a particular group whichever is less, shall be selected by the auditor for audit. Selection of tariff offerings for audit shall be done judiciously considering various parameters viz. number of active subscribers at the beginning of the quarter; number of active subscribers at the end of the quarter; subscription count for the tariff offering during the quarter etc. Auditor shall also record the justification, in audit report, against each tariff offering for selection or non-selection for the five most popular tariff offerings, in the respective annexures. 5.3.5 However, the compliance with the requirements contained in these regulations shall needs to be demonstrated only in relation to tariff offerings having material impact on the subscriber’s bill and the tariff offering shall be deemed to have material effect:

(i) where the service provider’s revenue from a tariff offering accounts for 5% or more of its total revenue from all the subscribers in the respective groups formed for sampling; or (ii) where the number of subscribers subscribing to a tariff offering offered by the service provider comprises 5% or more of the total subscriber base in the respective group formed for sampling; or (iii) at the specific direction of the TRAI.

Provided that the above materiality provisions shall not be applicable to any tariff offering having an impact on tariff of international call/ messages or call/ message/ data during international roaming.

5.3.6 The auditor shall collect the list of active subscribers at the end of the quarter under audit in all the five most popular tariff offerings from each group of each annexure, as selected above, from service providers. 5.3.7 The auditor shall select minimum of 1067 subscribers (in order to achieve a confidence level of 95% with margin of error of 3% for any population size) or total subscriber base of the group whichever is lower, on random basis, from each group in each annexure (I-A to I-D), provided the samples from five most popular tariff offerings are selected in proportion to their subscriber base. 5.3.8 Auditor shall also ensure that the random samples selected under each group are unique and same are not already covered in another group. In case of repetition of samples, equal number of new samples may be selected so that count of total samples remains unchanged. 5.3.9 In case, any tariff offerings viz. tariff plans, plan vouchers, special tariff vouchers, combo vouchers, top up vouchers, add-on plans are offered in multiple LSAs with exactly same configurations from same billing system, then the auditor may audit such tariff offers in one of the LSAs and in remaining LSAs alternate tariff offering of the same group may be selected for auditing of five most popular tariff offering of a group. 5.3.10 In case all the tariff offerings, under any group, have already been covered during audit of various LSAs served from same billing system and no unaudited tariff offerings is left in the group, then the process of selection of tariff offerings from such group shall be repeated in remaining LSAs served from same billing system.

5.4 STEP-4- Reconciliation of Billing Complaints

5.4.1 The auditor shall also undertake backward reconciliation of billing complaints both for post-paid and pre-paid subscribers to establish correctness of metering and billing system. 5.4.2 The auditor shall select 100 billing complaints or 10% of the total billing complaints from each LSA, comprising of different types, registered during the quarter, whichever is lower, on random basis. The auditor shall analyse these complaints in detail along with its resolution provided by the service provider. The auditor shall also verify whether the complainants are satisfied with the resolution provided, by making check back call. All such randomly selected subscribers, for audit of billing complaint, shall also be included for CDR/ IPDR audit. A log of such calls records made by the auditors shall be maintained along with calling number, called number, time and duration of call etc. and shall be submitted in case desired by the Authority.

5.5 STEP-5- CDR/IPDR verification

5.5.1 CDRs/ IPDRs/other service usage records etc. of all the subscribers as selected in step-3 and step-4 above shall be audited. 5.5.2 The auditor shall collect one-month raw CDRs/ IPDRs of all such subscribers. One month period shall coincide with the billing period for postpaid subscribers and plan cycle for prepaid subscribers. 5.5.3 In addition to collection of raw CDRs/ IPDRs, following details shall also be collected from the service provider:

(i) For postpaid subscriber: Bill of the corresponding period, account details of the subscriber at the beginning and end of the respective month along with changes, if any, during the month and details of policy applied, if any. (ii) For prepaid subscriber: account details of the subscriber at the beginning and ending of the month, all service/ recharge related transaction details viz. denomination, validity, attributes etc. with respect to the application of voucher (PV/STV/CV etc), charges deducted for each CDRs/ IPDRs during the month for which CDR/ IPDR is demanded and details of policy applied, if any.

5.5.4 The auditor shall rate the CDRs/ IPDRs of each subscriber as per its subscribed plan and details of plan filed to TRAI by the service provider and compare the same with the bill (for postpaid subscribers) and charges deducted (for prepaid subscribers) for the corresponding period. 5.5.5 The audit shall also include the verification of applying credits to the account (as per clause 5 of code of practice for metering and billing accuracy), application of top up voucher, charges related to VAS services, application of Fair/ Commercial Usage policies (FUPs/CUPs) in accordance with tariff offerings, service continuation till credit limit accorded to subscriber etc. 5.5.6 The auditor shall analyse the discrepancy, if detected, and find out the root cause of the same. All overcharging instances observed during the audit shall be reported to the service provider immediately. 5.5.7 The auditor shall also verify successful implementation of the corrective/ remedial action.

(Illustrative examples of various group formation and drawing samples are given at Annexure III)