TRAI regulation 4 of 2023 · 15 Sept 2023
Official title
The Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Fifth Amendment) Regulations, 2023
Official record
Open source pageSummary
The Telecom Regulatory Authority of India (TRAI) has amended the 2017 Interconnection Regulations to introduce technical and audit requirements for Digital Rights Management (DRM) and Subscriber Management Systems (SMS) for Internet Protocol Television (IPTV) services. Distributors (DPOs) must ensure real-time synchronization between SMS and DRM, maintain un-editable logs for at least three years, and implement robust content protection, including fingerprinting and copy protection. DPOs must ensure IPTV services are delivered within a closed network and that hybrid Set-Top Boxes (STBs) do not allow unauthorized access to linear channels via OTT apps or browsers. Existing systems are granted a three-month transition period from the date of commencement to comply with these new provisions.
What you must do
Key dates
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TO BE PUBLISHED IN THE GAZETTE OF INDIA, EXTRAORDINARY, PART III, SECTION 4 TELECOM REGULATORY AUTHORITY OF INDIA NOTIFICATION
THE TELECOMMUNICATION (BROADCASTING AND CABLE) SERVICES INTERCONNECTION (ADDRESSABLE SYSTEMS) (FIFTH AMENDMENT) REGULATIONS, 2023 (4 of 2023)
New Delhi, 14/09/2023
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 under 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, Part 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) 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 throughout 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 of their coming into force.
(a) in sub-regulation (6), after the 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.
(a) in sub-regulation (2), 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 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.
(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 the Schedule X or both, as the case may be,” shall be substituted.
“Schedule X (Refer sub-regulation (6) of the regulation 10, sub-regulation (7) of the regulation 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 regulations.
(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: |
(1) Must be less than 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 above 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 three (3) years or at least three audit cycles, or as per Schedule III whichever is later.
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 appropriate mechanisms or combinations thereof or alternatively user account has to be locked/paired to the Mac Id of the set top box (STB) /unique consumer subscription or the customer premises equipment (CPE)/device.
After-Sales Service Support: The required software and hardware support should be available 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
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.
Necessary and sufficient 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
DRM and SMS should be able to activate or deactivate services and/or STBs/unique consumer subscription of the subscriber base of the distributor within 24 hours.
The SMS shall be independently capable of generating, recording, and maintaining logs, for the period of at least immediately preceding three (3) consecutive years, corresponding to each command executed in the SMS including but not limited to activation and deactivation commands.
The SMS should be computerized and capable of recording all logs including information and data concerning 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 number (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.
The SMS should be capable of: (a) Viewing and 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 changes in the subscriptions for each subscriber and the corresponding source of requests made by the subscriber.
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/unique consumer subscription in the system. (f) Channel and bouquet wise monthly subscription report in the 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.
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.
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.
If there is active infrastructure sharing (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.
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 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/unique consumer subscription (active/Inactive)
The file output of DRM shall be processed by SMS system to compare and generate a 100% match or mismatch error report.
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 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).
Network Capacity Fee (NCF) Policy Creation: SMS shall support all NCF related requirements mandated by the applicable tariff order.
Bill/Invoice Generation: SMS shall be capable of generating proper subscriber bill/invoice with explicit details of NCF charges, pay channels 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).
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 subscription 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 independent servers.
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 capturing 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)
SMS shall be accessed through a Firewall
STB/unique consumer subscription and MAC ID shall be paired from the SMS to ensure security of channel (applicable for DRM with pairing facility).
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.
SMS should have a facility to carry out monthly reconciliations of channels/a-la-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.
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 activation status (g) Testing/demonstration STB/unique consumer subscription /MAC ID with location
Audit-related requirements: SMS should have the capability to capture below-mentioned information that may be required for audit and otherwise: (a) Subscriber related: (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 relation (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)
User Authentication: SMS should have the capability to authenticate its subscribers through registered mobile number (RMN) through one-time password (OTP) system
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 Subscriber 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 product 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 subscription. (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/Bouquet 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 with 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) Integrations, 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 operational 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).
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 backup 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 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 level information, etc.
