TRAI Pay-TV interconnection overhaul: Annual audits, 2-logo rule, stronger anti-piracy

The Telecom Regulatory Authority of India (TRAI) has issued the draft Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Seventh Amendment) Regulations, 2025, opening the proposal for public consultation. The move refreshes the interconnection framework that governs commercial and technical arrangements between broadcasters and distribution platform operators (DTH, MSO, HITS, IPTV) on addressable TV systems.

The draft rides on TRAI’s August 9, 2024 consultation on audit-related provisions in the 2017 Interconnection Regulations and the Digital Addressable Systems (DAS) Audit Manual. After reviewing stakeholder inputs, the regulator has framed amendments aimed at tightening audit scope, processes and reporting under the 2017 regime and is now seeking final feedback before notification. 

For industry, the changes matter because interconnection audits sit at the heart of subscriber reporting, revenue share, packaging and compliance between broadcasters and DPOs; a clearer, enforceable audit framework is expected to reduce disputes, improve transparency of subscriber data and strengthen settlement discipline across the pay-TV value chain.

A key proposal is to hard-wire an annual audit of every distributor’s addressable systems—SMS, CAS, DRM and related components—for the preceding financial year, with the final audit report to be shared with all connected broadcasters by September 30 each year. Audits must be conducted by BECIL or TRAI-empanelled auditors, with a 30-day advance intimation of the schedule and auditor to broadcasters; one broadcaster representative may observe the audit. Small distributors (≤30,000 active subscribers as on the last day of the prior financial year) may treat the audit as optional. The draft indicates the amendments would take effect from April 1, 2026 once notified.

TRAI also sketches a dispute-resolution ladder around audit findings. Where a broadcaster disagrees with the delivered report, it can file specific, evidenced observations; the distributor must route these back to the auditor for an updated report within 30 days. 

Persisting disagreements can be escalated to TRAI, which may permit a special audit at the broadcaster’s cost. If a distributor fails to share any audit report by the September 30 deadline, broadcasters may jointly or severally commission an audit at their cost, to be completed once a year within four months from that date. Where audits reveal subscriber number discrepancies, settlement follows the interconnect contract; if an addressable system fails the technical benchmarks (Schedules III/X), broadcasters may disconnect signals after three weeks’ notice.

Given widespread infrastructure sharing in the distribution ecosystem, the draft codifies shared-infra safeguards. Where SMS/CAS/DRM are shared, there must be separate instances per distributor and segregated data adequate for entity-wise reconciliation.

On anti-piracy identification, watermarking for pay channels should, where infrastructure is shared be done at the encoder end by the infra-provider, while the seeking distributor provides its network logo via STB/middleware; the consumer screen should ideally show only two logos (broadcaster + last-mile DPO). 

Complementing this, CAS must be capable of generating and retaining logs for at least two preceding years, and in shared-infra setups maintain separate command logs (including every activation/de-activation triggered by SMS) for each distributor.

If adopted as drafted, the seventh amendment would tighten audit discipline on a financial-year cycle, close long-standing grey zones in shared infrastructure, and sharpen enforcement levers around non-compliance, together signaling a push toward cleaner subscriber reporting and lower settlement friction across the pay-TV chain ahead of FY27. For DPOs, the trade-off will be higher process rigor; for broadcasters, greater confidence in reconciliations and piracy traceability.