Tata Play, Dish TV push TRAI to bring FAST channels under TV broadcasting rules

India’s leading direct-to-home (DTH) operators, including Tata Play and Dish TV India Limited, have urged the Telecom Regulatory Authority of India (TRAI) to bring application-based linear television distribution (ALTD) services and Free Ad-Supported Streaming Television (FAST) channels under the same regulatory framework applicable to traditional broadcasting and distribution platforms.

The submissions, made in response to TRAI’s consultation paper on “Formulation of a Regulatory Framework for Application-based Linear Television Distribution (ALTD) Services”, highlight growing concerns among legacy television distributors over what they describe as “regulatory arbitrage” benefiting internet-delivered television services.

The issue assumes significance as connected TVs, OTT-based linear channels and FAST services rapidly gain traction in India, enabling broadcasters and digital platforms to distribute television channels over internet-enabled applications without being subjected to the same licensing, content and advertising obligations imposed on DTH, cable and IPTV operators.

Tata Play calls for technology-neutral regulation

In a brief but pointed submission, Tata Play argued that regulation should apply uniformly irrespective of the technology used for content delivery.

“Content must be regulated or not regulated regardless of technology being used to deliver it,” the company said in its submission to TRAI. It added that “different technologies delivering the same content having different regulations lead to regulatory arbitrage.”

The company urged the regulator to either apply the “same regulatory regime” across all distribution technologies or remove such regulations uniformly for all players. The comments were signed by managing director and chief executive officer Harit Nagpal.

Tata Play’s intervention reflects mounting concerns within the pay-TV industry that internet-based television services are operating in a comparatively lighter regulatory environment even as they increasingly compete for the same audiences and advertising revenues.

Dish TV flags ‘regulatory vacuum’

Dish TV, in a more detailed response, argued that FAST channels and ALTD services have expanded in a “complete regulatory vacuum” despite distributing television-like linear content to Indian consumers.

The company noted that India’s uplinking and downlinking guidelines have historically required broadcasters to maintain Indian entities, obtain security clearances, disclose ownership structures and comply with programme and advertising codes. According to Dish TV, the emergence of FAST channels has effectively bypassed those safeguards.

The company further argued that several permitted satellite television channels are already being distributed through smart TVs and ALTD platforms, but are allegedly circumventing advertising restrictions applicable on traditional platforms.

Dish TV specifically referred to the Ministry of Information and Broadcasting’s advisory prohibiting condom advertisements between 6 am and 10 pm, claiming that such rules are routinely violated on internet-distributed television streams and OTT environments.

The company said this creates a situation where the “same channel” complies with programme and advertising codes on licensed DTH and cable networks, but effectively bypasses those obligations when delivered through ALTD services.

Push to classify ALTD platforms as DPOs

A key demand emerging from the submissions is that ALTD platforms should be treated on par with Distribution Platform Operators (DPOs), such as DTH, cable, IPTV and HITS operators.

Dish TV argued that any entity involved in the distribution of linear television content should fall within the DPO framework and comply with the same legal mandates applicable to traditional television distributors.

The company also proposed amendments to existing broadcasting guidelines to explicitly include web-based application providers and internet television distribution services within the definition of “Distribution Service Providers”.

Further, Dish TV supported TRAI’s suggestion that application providers play the central role in the ALTD ecosystem and therefore should be made responsible for obtaining authorisations for distributing television channels.

According to the company, application providers aggregate television channels and distribute them across smart TVs, mobile phones and tablets, effectively performing the role of a television distributor. It warned that some application providers are headquartered overseas while Indian entities neither control the content nor share in revenues generated from Indian distribution.

Demand for pan-India licensing model

Dish TV also recommended that ALTD services should operate under a pan-India authorisation regime similar to DTH and HITS services, rather than state- or circle-specific licensing structures.

The company argued that since ALTD services are accessible nationally over the internet, territorial licensing models would be impractical. A national framework, it said, would ensure “regulatory parity, level playing field and uniform compliance obligations.”

The company additionally suggested that smart TV manufacturers and operating system providers should ensure that only authorised ALTD applications are pre-installed or made accessible on their devices. It proposed annual compliance audits for such stakeholders.

Pricing, ratings and consumer protection concerns

On tariff and pricing, Dish TV maintained that television channels distributed via ALTD platforms should adhere to the same TRAI regulations applicable to conventional television distribution.

The company also called for ALTD platforms to be brought under existing quality-of-service and grievance-redressal norms applicable to DPOs, with technology-specific modifications introduced where necessary.

On audience measurement, Dish TV observed that digital environments generate far richer viewership data than traditional television ratings systems and suggested that ALTD providers should be permitted to publish periodic viewership data directly. However, it also proposed third-party audits by TRAI-empanelled auditors to address concerns around authenticity and transparency.

The company further said that hybrid ALTD business models — combining free FAST channels and paid television offerings — should also remain subject to the same regulatory prescriptions governing traditional broadcasters and distributors.

Regulatory debate intensifies

The submissions underscore the growing friction between legacy pay-TV operators and emerging internet-based television distribution ecosystems.

While DTH and cable operators argue that ALTD and FAST services are replicating television distribution without equivalent obligations, digital platforms have maintained that internet-delivered services require lighter-touch regulation to support innovation and consumer choice.

TRAI’s consultation is expected to shape India’s next-generation broadcasting framework as television consumption increasingly shifts toward connected devices and streaming-led distribution models.