Recommendations on Listing of television channels in Electronic

Recommendations

Listing of television channels in

Electronic Programme Guide

and

Upgradation of DD Free Dish platform to an

Addressable System

July 2024

World Trade Centre

, 5

& 7

Floor, Tower F

Nauroji Nagar

New Delhi-110029

Website: www.trai.gov.in

Telecom Regulatory Authority of India

INDEX

Chapter

No.

Topic

Page

No.

Introduction and Background

Listing of television channels in Electronic

Programme Guide

III

Roadmap for addressability of DD Free Dish

Summary of Recommendations

List of Acronyms

Annexure I

Annexure II

CHAPTER I

INTRODUCTION AND BACKGROUND

A. Extant Regulatory Framework of TRAI

1.1 Keeping in view the implementation of Digital Addressable Systems

(DAS) and to enable the sector to realize its benefits, the Telecom

Regulatory Authority of India (TRAI), after due consultation process,

published a ‘new regulatory framework’ for digital addressable systems

on 3

March 2017. This framework comprises of:

i. Telecommunication (Broadcasting and Cable) Services

Interconnection (Addressable Systems) Regulations, 2017

(hereinafter called “Interconnection Regulation 2017”),

ii. Telecommunication (Broadcasting and Cable) Services Standards of

Quality of Service and Consumer Protection (Addressable Systems)

Regulations, and

iii. Telecommunication (Broadcasting and Cable) Services (Eighth)

(Addressable Systems) Tariff Order, 2017

1.2 The new regulatory framework was notified in March 2017. However,

pursuant to legal challenges to the said regulations, the regulations

came into effect from 29

December 2018 after satisfying legal

pronouncements.

1.3 The framework brought about a paradigm shift to the television

distribution value chain. Transparency, non-discrimination and

revenue assurance to all stakeholders were the underlying principles of

the new framework. The framework enabled consumers, like never

before, with full control over their subscribed channels.

1.4 In order to address the issues noted during implementation of the

framework 2017, the Authority, after due consultation, notified the

following amendments to the Regulatory Framework 2017, on 1

January 2020:

i. The Telecommunication (Broadcasting and Cable) Services

Interconnection (Addressable Systems) (Second Amendment)

Regulations, 2020

ii. The Telecommunication (Broadcasting and Cable) Services

Standards of Quality of Service and Consumer Protection

(Addressable Systems) (Third Amendment) Regulations, 2020

iii. The Telecommunication (Broadcasting and Cable) Services (Eighth)

(Addressable Systems) Tariff (Second Amendment) Order, 2020

B. The current Consultation Paper

1.5 To address certain issues arising out of implementation of amendments

to regulatory framework, TRAI issued a Consultation Paper on Review

of Regulatory Framework for Broadcasting and Cable services on 8

August 2023 (hereinafter called “consultation paper”).

1.6 Comments were received from 86 stakeholders. The Open House

Discussion (OHD) in online mode was held on 18

April 2024. The

comments and the OHD submissions have been analysed, and as an

outcome of the consultation paper, certain amendments have been

notified in the regulatory framework. Further, after careful examination

of the stakeholders’ comments, it has been found that two issues related

to the listing of television channels in the Electronic Programme Guide

(EPG) of the Distribution Platform Operators (DPOs) and non-

addressable platform of DD Free Dish of public service broadcaster need

to be addressed by issuing recommendations to the Government.

C. Listing of television channels in EPG

1.7 In addressable systems, the technology provides for an EPG wherein

the television channels being carried on a DPO’s network can be

arranged in a simple and easy to understand manner so that the

subscriber can easily go through this guide and select the channel of

choice instead of flipping through all the channels.

1.8 In the Interconnection Regulation 2017 (as amended), the broadcasters

have been given freedom to declare the genre of their television channels

and in terms of the regulations, it has been mandated that a DPO shall

place the channels in the EPG under the respective genres so declared

by the broadcasters. Further it has also been mandated that DPOs shall

place all the channels available on its platform in the EPG, in such a

manner that all the channels of a particular language in a genre are

displayed together consecutively and one television channel shall

appear at one place only.

1.9 In this regard, the Authority received several complaints regarding out

of genre running of television channels by distributors. TRAI analysed

the data of many distributors and all of them were found to be in non-

compliance with provisions of Interconnection Regulation 2017 (as

amended). Upon enquiring the reasons behind non-compliance, the

distributors informed TRAI that MIB gives permission to a channel in

multiple languages. Sometimes, some television channels run programs

in multiple languages. Therefore, distributors find it difficult to comply

with provisions of Interconnection Regulation 2017 (as amended)

especially in case of free-to-air (FTA) channels.

D. Introduction to Prasar Bharati

1.10 Prasar Bharati, India’s public service broadcaster was established

following the enactment of the Prasar Bharati (Broadcasting

Corporation of India) Act, 1990

by the Parliament of India. Prasar

Bharati operates its broadcasting network to fulfil its mandate of public

service broadcasting.

1.11 Section 12 (1) of the Prasar Bharati Act specifies the main function of

Prasar Bharati in the field of radio and television broadcasting as:

“Subject to the provisions of this Act, it shall be the primary duty of the

Corporation to organise and conduct public broadcasting services to

inform, educate and entertain the public and to ensure a balanced

development of broadcasting on radio and television.

https://prasarbharati.gov.in/prasar-bharati-act/

Explanation — For the removal of doubts, it is hereby declared that the

provisions of this section shall be in addition to, and not in derogation,

of the provisions of the Indian Telegraph Act, 1885.”

1.12 The Prasar Bharati Act defines broadcasting as follows:

“broadcasting” means the dissemination of any form of communication

like signs, signals, writing, pictures, images and sounds of all kinds

by transmission of electro-magnetic waves through space or through

cables intended to be received by the general public either directly or

indirectly through the medium of relay stations and all its grammatical

variations and cognate expression shall be construed accordingly;”

1.13 Prasar Bharati owns and operates a Free-to-Air (FTA) Direct-to-Home

(DTH) service namely DD Free Dish (erstwhile DD Direct+) since 2004,

an approved scheme of the Government of India. DD Free Dish is an

alternative affordable platform for people who do not have means to pay

subscription fee of private DTH and cable platforms. DD Free Dish,

leveraging its DTH technology reaches to millions of people especially in

rural, remote, inaccessible and border areas having low income and is

used as a tool not only for entertainment but also for promoting

education, health and agriculture.

D1. Background of DD Free Dish

1.14 The Ministry of Information and Broadcasting (MIB) in 2003 had

granted permission to Prasar Bharati to use satellite distribution

technology in the Ku-band frequency (12-18 GHz) for providing DTH

service for offering bouquet of TV channels consisting of 20 channels of

Doordarshan and 10 channels of private broadcasters, in FTA mode.

1.15 Prasar Bharati had started its DTH service named DD Direct+ in

December 2004, which was re-named to DD Free Dish on 27

August

2013. Initially the coverage of DD Free Dish was confined to Himachal

Pradesh, Chhattisgarh, Karnataka, Madhya Pradesh, Rajasthan,

Uttaranchal, northeast region and Gujarat, i.e., where the percentage

of TV broadcasting services coverage was below national average.

However, at present, the coverage of DD Free Dish services is

throughout the Indian territory except Andaman & Nicobar Islands.

1.16 The capacity of DD DTH platform was enhanced from 30 to 40 TV

channels on in 2004. The bouquet available consisted of 17 channels

of Doordarshan and 23 channels of private TV broadcasters. The

capacity of DD Free Dish platform kept expanding from time-to-time.

After 6

annual (75

) e-auction, i.e., with effect from 01.04.2024 there

are total 167 TV channels consisting of 94 MPEG-2

channels, 22

MPEG-4

channels, 51 educational channels

of Bhaskaracharya

National Institute for Space Application and Geo-Informatics (BISAG)

and 48 Radio channels, available on the DD Free Dish platform. The

list of all these available channels may be referred from Annexure I.

1.17 Earlier, Doordarshan used to provide terrestrial television through High

Power High Tower (HPHT) television towers and the consumer could

receive the signal by installing a Yagi Antenna purchased from the

market. The purpose was that any consumer can receive the signal free

of charges and without any subscription cost or Know Your Customer

(KYC) details, thus facilitating mass reach of the Doordarshan television

service to the people.

1.18 With the passage of time, the terrestrial TV transmitters, which were

required to be placed in each district, could not proliferate and started

declining. DD Free Dish made those transmissions available through

satellite means to every nook and corner of the country. In place of Yagi

antenna, now the consumer needs to place a small aperture parabolic

antenna to receive the DD Free Dish signals and a set top box to act as

TV channel tuner.

D2. Process of carriage of television channels on ‘DD Free Dish’

1.19 Initially private TV channels were chosen randomly for carrying on DD

Free Dish platform and no fee was charged from private channels for

initial two years. In January 2007, a Core Group, consisting of senior

https://prasarbharati.gov.in/wp-content/uploads/2024/03/MPEG-2-LCN-Line-up.pdf

https://prasarbharati.gov.in/wp-content/uploads/2024/03/After-6th-76th-e-Auction-LCN-Lineup-

of-MPEG-4-Channels-from-01.04.2024.pdf

https://prasarbharati.gov.in/wp-content/uploads/2024/04/DD-Free-Dish-LCN-Line-up.pdf

officers of Prasar Bharati, was constituted to revamp the DD Direct+

(now DD Free Dish) DTH Platform and to decide the carriage fee to be

charged from private broadcasters, whose channels are carried in the

bouquet. The selection of private channels for placement on DD Free

Dish was done by the Core Group amongst the applicant channels

based on the genre of the channels.

1.20 Some broadcasters approached Telecom Disputes Settlement and

Appellate Tribunal (TDSAT) contending that process of selection of

channels on Free Dish platform is not transparent. The TDSAT vide

judgment dated 16

December 2010, in Petition Nos. 407 (c) of 2010,

410 (c) of 2010 and 416 (c) of 2010 filed by some of the broadcasters,

directed Prasar Bharati to frame a transparent policy for the placement

of channels on DD DTH Platform.

1.21 On 7

June 2011, Prasar Bharati approved an e-auction policy for the

placement of private TV channels on DD Free Dish platform.

Subsequently, Prasar Bharati Board in its 150

meeting approved

guiding principles for framing new methodology for allotment of slots of

DD Free Dish to private TV channels. Based on the approved guiding

principles, Prasar Bharati notified revised e-auction methodology with

differential pricing based on genre (language) for carriage of private

channels on DD Free Dish on 15

January 2019, which were amended

subsequently from time to time.

1.22 Initially only MPEG-2 technology was used by Prasar Bharati for

providing DD Free Dish services. In 2019, Prasar Bharati introduced

MPEG-4 technology for DD Free Dish and conducted e-auction for

MPEG-4 slots also. Reserve price for MPEG-4 slots for channels of all

genres was fixed at Rs. 5 lakh which were increased to Rs. 50 Lakh on

February 2021.

1.23 As per information available on the website of Prasar Bharati

, 78 e-

auctions have been conducted so far by Prasar Bharati for allotment of

DD Free Dish slots to private satellite TV channels.

https://prasarbharati.gov.in/free-dish-4/

1.24 Private satellite channels which are permitted by the MIB are allowed

to participate in the e-auction. Private satellite TV channels desirous of

placing their channels on DD Free Dish are allowed to bid only in e-

auctions specific to the genre and language they belong to. For this

purpose, broadcasters are required to declare genre and language of

their channel(s) to Prasar Bharati while applying for e-auction to be

eligible to participate, and if successful, are provided a slot, generally

valid from 1

April of a particular year to 31

March of the next year.

1.25 Since the platform is non-addressable, in terms of subscribers, no

authentic data is available for DD Free Dish viewership. Different

industry reports reflect different number of viewers. As per an industry

report

around 45 million viewers/consumers are watching television

through DD Free Dish connection.

D3. Applicability of Regulations and Orders notified by TRAI on Prasar

Bharati

1.26 TRAI Act, 1997 defines ‘service provider’ and ‘licensee’ as follows:

“ ‘service provider’ means the Government as a service provider and

includes a licensee;

‘licensee’ means any person licensed under sub-section (1) of section

4 of the Indian Telegraph Act, 1885 (13 of 1885) for providing

specific public telecommunication services;”

1.27 The Government in the year 2000 amended the TRAI Act, 1997 and

included the proviso to section 2(1)(k) that enabled the Central

Government to notify other service to be telecommunication service

including broadcasting services.

1.28 In exercise of the powers conferred by the proviso to section 2(1)(k) of

TRAI Act, 1997, the Central Government issued gazette notification S.O.

44 (E) on 9

January 2004, notifying the broadcasting services and

cable services to be telecommunication service.

https://assets.ey.com/content/dam/ey-sites/ey-com/en_in/topics/media-and-

entertainment/2023/05/ey-me-report.pdf

1.29 Central Government vide Notification S.O. 45 (E) dated 09.01.2004

entrusted the following additional functions to TRAI in respect of

broadcasting services and cable services:

“(1) Without prejudice to the provisions contained in clause (a) of Sub-

section (1) of Section 11 of the Act, to make recommendation

regarding–

(a) the terms and conditions on which the “Addressable systems”

shall be provided to customers

(b) the parameters for regulating maximum time for advertisements

in pay channels as well as other channels.

(2) Without prejudice to the provisions of Sub-section (2) of Section 11

of the Act, also to specify standard norms for, and periodicity of,

revision of rates of pay channels, including interim measures.”

1.30 Some broadcasters filed a petition before TDSAT in August 2008,

challenging the carriage fees charged by Prasar Bharati as legally not

valid and contesting that TRAI’s Regulations should be applicable to

Prasar Bharati.

1.31 Hon’ble TDSAT in the petitions No. 183 (C) of 2008, 195 (C) of 2008 and

216 (C) of 2008, in its para 34

held that Prasar Bharati is a licensee

under the Indian Telegraph Act, thereby establishing its categorization

as a 'service provider' under section 2(j) of the TRAI Act. Para 34 held

that:-

“... In sum, therefore, the contentions of the 1

Respondent, Prasar

Bharati, regarding this Tribunal not having the jurisdiction to settle

the petitions herein fail. We hold, for the reasons discussed above,

that Prasar Bharati is a licensee u/s 4 of the Indian Telegraph Act

and being a licencee, that Prasar Bharati is covered under the

definition of 'service provider' in section 2 (j) of the TRAI Act. …” ;

https://tdsat.gov.in/Delhi/services/judgment.php

E. Structure of the Document

1.32 Based on the written comments received, inputs provided by the

stakeholders during the OHD and their analysis, the Authority has

finalized these recommendations. The recommendations have been

spread over four chapters. Chapter I provides the Introduction. Chapter

II discusses the issues related to listing of channels in Electronic

Programme Guide (EPG). Chapter III discusses the roadmap for

upgradation of DD Free Dish to an addressable system. Chapter IV

summarizes the Authority’s recommendations on the subject.

CHAPTER II

LISTING OF TELEVISION CHANNELS IN ELECTRONIC

PROGRAMME GUIDE

2.1 According to regulation 18 of the Interconnection Regulation 2017:

“Listing of channels in electronic programme guide.— (1)

Every broadcaster shall declare the genre of its channels and such

genre shall be either ‘Devotional’ or ‘General Entertainment’ or

‘Infotainment’ or ‘Kids’ or ‘Movies’ or ‘Music’ or ‘News and Current

Affairs’ or ‘Sports’ or ‘Miscellaneous’.

(2) It shall be mandatory for the distributor to place channels in the

electronic programme guide, in such a way that the television

channels of same genre, as declared by the broadcasters, are

placed together consecutively and one channel shall appear at one

place only:

Provided that all television channels of same language within the

same genre shall appear together consecutively in the electronic

programme guide:

Provided further that it shall be permissible to the distributor to

place a channel under sub-genre within the genre declared for the

channel by the broadcaster.”

2.2 Subsequently, distributors of television channels (or distributors)

raised certain issues in adhering to the prescribed structure of the

EPG. Accordingly, the Authority, after due consultation, amended

the above-mentioned provisions of Regulation 18(2) of

Interconnection Regulation 2017, on 1

January 2020, to read as

follows:

“(2) It shall be mandatory for the distributor to place all the

television channels available on its platform in the electronic

programme guide, in such a manner that all the television channels

of a particular language in a genre are displayed together

consecutively and one television channel shall appear at one place

only.”

2.3 Similar provisions exist in the Telecommunication (Broadcasting

and Cable) Services Standards of Quality of Service and Consumer

Protection (Addressable Systems) Regulations, 2017 (as amended).

2.4 As mentioned earlier, TRAI received certain complaints regarding

out of genre running of channels by distributors. TRAI analysed

data of some distributors and it was found to be in non-compliance

with provisions of Interconnection Regulation 2017 (as amended).

Upon enquiring the reasons behind non-compliance, the

distributors informed TRAI that MIB gives permission to a channel

in multiple languages. Sometimes, some television channels run

programmes in multiple languages. Therefore, distributors find it

difficult to comply with provisions of Interconnection Regulation

2017 (as amended) especially in case of free-to-air (FTA) channels.

2.5 In the consultation paper, one of the issues raised for consultation

was regarding listing of channels in EPG and the question raised

was as below:

Q17. Should flexibility be given to DPOs for listing of channels in

EPG?

a. If yes, how should the interest of broadcasters (especially

small ones) be safeguarded?

b. If no, what criteria should be followed so that it promotes

level playing field and safeguard interest of each

stakeholder?

Comments of the Stakeholders

2.6 In response, many stakeholders stated that flexibility should be

given to DPOs for listing of channels in EPG since the DPOs

understands the consumer preferences with respect to the

language/channel. Some stakeholders further opined that the move

to regulate the EPG channel placement infringes upon the

fundamental business autonomy of DPOs. Essentially, it is an

inherent right of any platform operator to optimize and monetize its

platform. One stakeholder opined that level playing field is already

skewed against the DPOs and proposals like regulating EPG would

further skew it as this measure is against the business autonomy

of DPOs and further, requested TRAI to ignore such suggestions and

not irreparably harm a vital stakeholder by impinging on its

autonomy by unnecessary micromanagement. Another stakeholder

opined that just as broadcasters have the discretion to sequence

their programmes and advertisements, DPOs should be afforded the

same autonomy in structuring their EPGs. This is a fundamental

aspect of their business operations, allowing them to differentiate

themselves in a competitive market.

2.7 Other group of stakeholders expressed that flexibility should not be

given to DPOs for listing of channels in EPG. One stakeholder

propounded that safeguards should be built into the regulations to

mandate that all channels of the same genre and language be listed

together and numbered consecutively/sequentially in both the

logical channel number (LCN) and EPG. TRAI should require DPOs

to report their channel line-up in the EPG and LCN to TRAI and

relevant broadcasters may monitor compliance and avoid misuse by

smaller and independent DPOs.

2.8 Another stakeholder opined that TRAI may ask the broadcasters to

specify the primary genre and language of the channel for the

purpose of arrangement of EPG. Then DPO would have to

mandatorily put channel as per defined language and genre.

Another stakeholder submitted that EPG should have a logical

numbering which should be easy for the viewers. There is good

flexibility presently with the DPOs in terms of placement of channels

in genre-language combinations.

2.9 One of the views expressed in the consultation process was that

TRAI may prescribe a fair, reasonable, and non-discriminatory

basis for the allocation of EPG and LCN in such a manner that there

is no discrimination or arbitrariness being exercised by the DPO.

While doing so, the existing broadcasters should be allowed to

continue on the same EPG and LCN. Another view expressed was

that for better viewing experience for consumers, listing should start

with language followed by genre rather than the other way round,

which is prevalent today.

2.10 One association submitted that the Authority has given adequate

flexibility to the DPOs to place their channel on their EPG once their

language and genre is defined by the broadcaster. Authorities

should continue to monitor the same to prevent the DPOs from

misusing the flexibility granted to them.

2.11 One stakeholder advocated to follow forbearance and permit market

forces to prevail and follow same light touch regulatory approach

for the broadcasting sector as was applied in the telecom sector.

2.12 In the consultation paper, one of the issues for consultation was as

follows:

Q18. Since MIB generally gives permission to a channel in multiple

languages, how the placement of such channels may be

regulated so that interests of all stakeholders are protected?

2.13 In response, some stakeholders opined that flexibility should be

with the DPOs, as the DPOs understand the consumer preferences

with respect to the language/channel. Some other stakeholders

submitted that broadcasters are required to declare the genre and

the language while declaring the channels under RIO. In case, a

channel has more than one language, then the primary language or

the first language of the channel declared by the broadcaster should

be considered by DPOs for placing the channel at appropriate place

in the EPG.

2.14 One stakeholder expressed that any mandate on EPG needs to be

reconsidered and removed, however, if TRAI has a divergent view,

then the channels should be clubbed in the form of a single genre

irrespective of language. A majority of subscribers tend to browse

for their preferences using genres, therefore, in the interests of

subscribers, channels should be clubbed in the form of a single

genre irrespective of language. Another stakeholder stated that only

for multi-lingual channels DPOs may be allowed to place channels

in such language group which is based on the majority language

spoken in their area of operation, i.e., state-wise listing can be

allowed. Further, one stakeholder opined that there should be a

separate section on multiple languages. This section will mostly

have Infotainment, Kids and Sports channels which are available in

multiple languages. Multiple languages channels can alternatively

be part of a particular language section provided they declare that

language as its primary language.

2.15 Few stakeholders opined that it should be left to the understanding

of Broadcaster and DPO. Further, there should be no discrimination

between the channels of multiple languages. One stakeholder

submitted that a channel running programmes in multiple

languages should be allowed to choose the language under which it

wishes to be listed and accordingly that should be followed. Some

other stakeholders opined that DPOs should be given freedom to

place the channels in the genre declared by the broadcasters but in

the sub-genre finalized by the DPO (based upon language) and the

placement sequence may be counted on the basis of sub-genre.

2.16 One of the views expressed was that one possible solution is to allow

a channel to be placed in the EPG as per the primary language of

the content it shows. The other solution is to promote consumer

choice by allowing a consumer to customize their EPG as per their

language preference. Another stakeholder opined that choice

should be given to the user to select the appropriate language from

the STB Remote Control Unit (RCU) button. This will go a long way

in helping with channels capacity and optimize the total bandwidth.

Another view was that MSO should clearly show all channels with

the same language, so that it is easy for the customer. Another

stakeholder suggested that TRAI may prescribe a fair, reasonable

and non-discriminatory basis for allocation of EPG and LCN in such

a manner that there is no discrimination and arbitrariness being

exercised by the DPO.

Analysis of the comments and views of the Authority

2.17 The primary objective to regulate the EPG include the following:

a. To ensure ease of viewing the television channels by consumer.

b. To provide flexibility to the distributors to arrange the television

channels as per regional/local requirements.

c. To ensure that fair treatment is given to broadcasters to place

their channels appropriately in respective genre to get the

viewership.

d. To ensure that the DPOs wilfully do not place channel of few

broadcasters out of genre to reduce their adoption by

subscribers/viewership.

2.18 Considering these objectives, the Authority had decided that the

distributors should have flexibility to list the channels in the EPG

to some extent to meet the requirement of the subscribers while

broadly protecting the interest of broadcaster. Accordingly, the

extant provisions provide that distributor will have flexibility to

organise the channel on EPG based on Language (L) or Genre (G)

ensuring that pair of a channel of the language and the genre

remains together. The distributor can devise its own plan with a

combination but should keep channels of same language & same

genre together as a single group.

2.19 However, as mentioned earlier, distributors have informed TRAI

that they find it difficult to comply with provisions of

Interconnection Regulation 2017 (as amended) as MIB gives

permission to a channel in multiple languages and sometimes,

some television channels run programmes in multiple languages.

They informed TRAI that especially in case of free-to-air (FTA)

channels, this problem is more pronounced.

2.20 The Authority is of the view that the extant framework provides

adequate flexibility to the distributors in organising the channel in

the EPG. It also ensures that broadcaster of each genre and

language are given adequate protection from any malfeasance and

arbitrariness.

2.21 However, it is pertinent that the distributor should know Genre and

primary language of all channels including FTA channels to arrange

each channel in EPG accordingly. Since MIB gives downlinking

permission to each and every channel, the Authority is of the view

that MIB should get information from broadcasters about sub-

Genre of non-news channel (as per Regulation 18(1) of

Interconnection Regulation 2017 (as amended)) and primary

language of the channel while giving permission to each channel

and display the same on its website.

2.22 In view of the above, the Authority recommends that Ministry of

Information and Broadcasting (MIB) should seek information

from broadcasters about primary language of their television

channel and sub-genre of every non-news channel (as per

Regulation 18(1) of Interconnection Regulation 2017 (as

amended) notified by the Authority) while giving permission to

each channel. The Authority also recommends that the

information so obtained may be displayed on Broadcast Seva

portal of MIB so as to enable the distributors to arrange each

channel in EPG accordingly.

2.23 The Authority further recommends that MIB may seek the

above information also for the existing permitted channels of

broadcasters and display the same on Broadcast Seva portal of

MIB so that the existing channels may also be arranged

appropriately in EPG by the distributors.

CHAPTER III

ROADMAP FOR ADDRESSABILITY OF DD FREE DISH

3.1 To avail the broadcasting services of DD Free Dish, the consumer has

to purchase Consumer Premise Equipment (CPE) including Set-Top-

Box (STB) and a small sized dish antenna from the open market. This

requires a one-time investment of around Rs. 2000 and the services are

available with no additional subscription cost. However, the quality of

consumer premise equipment may not be guaranteed and the STBs so

obtained may be susceptible to piracy. As a result, the quality of viewing

experience deteriorates for the consumers. Moreover, due to its non-

addressable nature, the actual number of DD Free Dish subscribers

cannot be determined. Further, TRAI’s regulatory framework which is

applicable to addressable systems only, is not applicable to DD Free

Dish which is a non-addressable system.

A. Non-applicability of 2017 regulatory framework and

availability of ‘pay channels’ on DD Free Dish

3.2 In the said consultation paper, TRAI has also raised issues pertaining

to non-level playing field and non-addressability of DD Free Dish vide

question numbers 11, 12 and 13.

Comments of the Stakeholders

3.3 Question 11 of the consultation paper reads as under:

Q11. Should Tariff Order 2017, Interconnection Regulations 2017 and

Quality of Service Regulations 2017 be made applicable to non-

addressable distribution platforms such as DD Free Dish also?

3.4 In response, majority of the stakeholders, particularly the DPOs

including both DTH operators and MSOs have strongly advocated for

making the DD Free Dish platform addressable, thereby subjecting it to

TRAI’s regulatory framework of broadcasting and cable service of 2017.

They mentioned that DD Free Dish has ventured beyond its initial

mission, transitioning into a commercial entity that capitalizes on its

network capacity. DD Free Dish allots its slots to broadcasters through

e-auctions, whereas private DPOs are not allowed to auction their

network capacity, instead are mandated through regulations to provide

their network on first come first serve basis to broadcasters.

3.5 In contrast, Prasar Bharati alongwith few broadcasters through their

comments have submitted that DD Free Dish is a free-to-air, non-

addressable system and hence 2017 regulatory framework is not

applicable on DD Free Dish. They added that upgrading DD Free Dish

to an addressable platform would incur huge cost. The stakeholders

further mentioned that Tariff Order is applicable only to a pay and

addressable platform, wherein money is collected either by way of

carriage fee from broadcasters or by subscription fee for a specified

channel/bouquet opted by the subscribers. While Prasar Bharati’s DTH

platform being completely free to air, no tariff order is required at all.

3.6 Regarding Interconnection Regulations, they further commented that

considering the unique nature of DD Free Dish, its capacity constraints

and the manner of allocation of slots by e-auction, there is no need for

the Interconnection Regulations to be made applicable to DD Free Dish.

Interconnection Regulations are incompatible with the structure and

functioning of DD Free Dish.

3.7 In so far Quality of Services and Consumer Protection Regulations,

stakeholders opined that such regulations deal with various charges for

installation, activation, restoration, reactivation, visiting and relocation

and provisions like display of Maximum Retail Price (MRP) on EPG,

setting up of a customer care centre, provision of toll-free number,

establishment of website, CPE schemes, billing, maintenance of

services, etc. Such requirements are not applicable on free to air non-

addressable platform like DD Free Dish.

3.8 TRAI has notified the Telecommunication (Broadcasting and Cable)

Services (Eighth) (Addressable Systems) Tariff Order, 2017 (Tariff Order

2017) as amended. Clause 3(2) of Tariff Order 2017 is as follows:

“(2) Every broadcaster shall declare ----

(a) the nature of each of its channel either as ‘free-to-air’ or ‘pay’; and

(b) the maximum retail price, per month, payable by a subscriber for

each of its pay channel offered on a-la-carte basis:

Provided that the maximum retail price of a pay channel shall be

more than ‘zero’:

Provided further that the maximum retail price of a channel shall

be uniform for all distribution platforms.”

3.9 As per the above clause, a broadcaster is free to declare its channels as

Pay or FTA. In case of a pay channel, the broadcaster is required to

declare its MRP, which has to be uniform for all distribution platforms.

In this regard, Clause 1(2) of the Tariff Order 2017 is reads as under:

“(2) This Order shall be applicable to broadcasting services relating to

television provided to subscribers, through addressable systems,

throughout the territory of India.”

3.10 The above clause suggests that the Tariff Order 2017 applies exclusively

to addressable systems. Given that DD Free Dish operates as a non-

addressable platform, the provisions of Tariff Order 2017 do not extend

to it. Consequently, this allows for the availability of pay channels of

broadcasters on the DD Free Dish platform as free to air. Due to this

disparity, the CP raised the following question:

Q12. Should the channels available on DD Free Dish platform be

mandatorily made available as Free to Air Channels for all the

platforms including all the DPOs?

Comments of the stakeholders

3.11 Q12 of the consultation paper deals with the issue of channels declared

as ‘pay’ by the broadcasters but are available as free to the consumers

of DD Free Dish with no subscription cost. Stakeholders expressed their

concerns regarding this phenomenon of availability of pay channels on

DD Free Dish is resulting in a non-level-playing field between DD free

Dish and other private DPOs. They demanded that either pay channels

should be entirely unavailable on the DD Free Dish platform or, if

available, they should be declared as FTA by the broadcasters across

all distribution platforms.

3.12 The stakeholders mentioned that subscribers of other DPOs should not

be made to pay for the same channel which is being enjoyed for free by

the subscribers of DD Free Dish. Uniform pricing across DPOs and DD

Free Dish needs to be promoted. To maintain the integrity of the

broadcasting sector, ensure fair competition and uphold consumer

interests, it is imperative that channels maintain their designated

status (be it ‘pay’ or ‘FTA’) consistently across all DPOs.

3.13 On the other hand, Prasar Bharati and the other stakeholders

advocated that Prasar Bharati is a distinct entity vis-a-vis other private

DPOs, since it is not similarly placed either under law or regulatory

regime. The number of pay channels that use DD Free Dish is a

minuscule number of 20, which does not warrant any intervention by

the Regulator.

Analysis of the comments and views of the Authority

3.14 Based on the Guiding Principles of e-auction methodology

laid by

Prasar Bharati, broadcasters participate in an e-auction to place their

channels on DD Free Dish Platform. Such channels of the broadcasters

are categorized under various buckets as per genre and language of the

TV channels, as attached at Annexure II. Presently, 75

private

television channels are available on DD Free Dish platform permitted

by MIB, of which 20 channels are declared as ‘pay’ channels by the

respective broadcasters. However, these 20 channels are available at no

monthly subscription cost to the consumers of DD Free Dish.

3.15 The stakeholders have submitted that the existing price disparity of the

pay TV channels among private DPOs and DD Free Dish has resulted

into loss of subscriber base of the private DPOs, as more and more

https://prasarbharati.gov.in/wp-content/uploads/2023/12/E-auctionmethodology27-01-2023.pdf

https://prasarbharati.gov.in/wp-content/uploads/2024/04/Genre-wise-Channels-on-DD-Free-

Dish-as-on-10.04.2024.pdf

consumers are shifting on DD Free Dish platform, wherein both FTA

and pay channels are available without any monthly charges.

3.16 To address this disparity, the Authority has amended the relevant

clause in the Tariff (Fourth Amendment) Order, 2024. In clause 3 of the

principal Tariff Order, in sub-clause (2b), after the second proviso, the

following proviso has been inserted, namely:

"Provided that a channel, which has been granted downlinking

permission by the Central Government and is available at no

subscription fee on the direct to home platform of the public service

broadcaster, shall not be declared as pay channel for addressable

distribution platforms."

B. Addressable system

3.17 Addressability is an efficient and effective way to transmit television

signals in an encrypted form, which can be decoded by the STBs at the

consumer premises within the limits of the authorization made. These

addressable STBs are procured from authorised sources which ensures

quality of viewing experience to the consumers. Such STBs prevent

unauthorized re-transmission/distribution of television channels,

manage subscriber information and enhances overall service quality.

3.18 Question No. 13 raised the requirement of DD Free Dish platform to

addressable system, which is reproduced as under:

Q13. Whether there is a need to consider upgradation of DD Free Dish as

an addressable platform? If yes, what technology/ mechanism is

suggested for making all the STBs addressable? What would be the

cost implications for existing and new consumers? Elaborate the

suggested migration methodology with suggested time-period for

proposed plan. Please provide your response, with justification.

Comments of the Stakeholders

3.19 Regarding the need for addressability and migration to the addressable

platform, stakeholders commented that to establish a level playing field,

it is imperative to subject it to the TRAI regulatory framework. This

necessitates transitioning DD Free Dish into an addressable platform.

Some LCO associations mentioned that this change will benefit all

stakeholders including customers as increase in competition always

pays positive dividends for customers. They flagged that DD Free Dish

has been functioning in violation of DAS regulations and is also against

the rights of equality and right of justice and livelihood of cable

operators. Few stakeholders mentioned that there have been instances

in the past where the distribution of channels on DD Free Dish has

occurred illegally and without authorization. Once made addressable,

and fall within the regulatory ambit, this piracy would be effectively

halted.

3.20 They further opined that addressability would allow for tracking

viewership patterns like consumer consumption patterns, content

planning, advertisement targeting, providing consumers with better

quality of service. No platform or entity, irrespective of ownership,

intent, market or target audience should be allowed to offer channels or

services in a non-addressable mode as it is against the law.

Analysis of the issue and views of the Authority

B1. Upgradation of DD Free Dish to an addressable system

3.21 As per the extant regulatory framework of TRAI, addressable system is

defined as follows:

‘addressable system means an electronic device (which includes

hardware and its associated software) or more than one electronic

device put in an integrated system through which transmission of

programmes including re-transmission of signals of television channels

can be done in encrypted form, which can be decoded by the device or

devices at the premises of the subscriber within the limits of the

authorization made, on the choice and request of such subscriber, by the

distributor of television channels.’

3.22 Addressability is the ability of a digital device to individually respond to

a message sent to many similar devices. In the television distribution

framework (DTH or cable or through IPTV etc.) an addressable system

enables and controls the distribution of television channels, by

encrypting the signal and ensuring only authorized users can receive

channels using a STB and TV set.

3.23 Addressable STBs enable efficient transmission of television signals

through an STB installed at the customer's premises, facilitating

conditional access and ensuring content security. Further, STBs

provided by authorized manufacturers and distributors would be of

good quality and come with after sales services also, resulting in value

for money to the subscribers. Moreover, use of a Subscriber

Management System (SMS) linked to the STB enables the generation of

accurate subscriber-wise data, management of subscriber information,

channel details and other related activities, thereby enhancing the

quality of service provided to subscribers.

3.24 Presently, there is no effective mechanism to identify and verify the

number of subscribers accessing DD Free Dish services. While some

industry reports indicate there are 45 million

households with DD

Free Dish, others indicate some other numbers. This discrepancy in

subscriber data highlights the need for addressability. Implementing

addressability would allow for accurate tracking and verification of

subscriber numbers. Addressability would thus provide a much-needed

breakthrough to resolve the current inconsistencies by providing a

reliable count of households using the DD Free Dish service.

3.25 The Authority has been informed that certain operators utilize the

unencrypted feed from DD Free Dish connections and re-transmit these

signals to their customers, charging a fee determined by the operator.

Since, there is no check/curbing mechanism deployed by DD Free Dish,

certain set of customers get these pirated channels at their premises.

3.26 It may be noted that the introduction of DAS has enabled

addressability, transparency, high channel carrying capacity and

provided technical feasibility to offer choice to the consumers. In a DAS

https://assets.ey.com/content/dam/ey-sites/ey-com/en_in/topics/media-and-

entertainment/2024/ey-in-india-s-media-entertainment-sector-is-innovating-for-the-future-03-2024-

v1.pdf

based environment, CAS and SMS are an integral part and the quality

of service is dependent on the CAS and SMS systems. Under a

conditional access system, only an authorized receiver/STB can decrypt

the broadcast content. Essentially, CAS ensures that content delivery

pipe from the operator to the STB is secured and provides a mechanism

of addressing each STB uniquely. Whereas SMS primarily stores and

manages details of each subscriber and the TV channels that are

subscribed to by the subscriber.

3.27 Therefore, the Authority believes that to leverage the potential benefits

of the addressable system, DD Free Dish platform needs to be upgraded

to addressable systems in a time-bound manner with a defined sunset

date. MIB should notify the upgradation of Prasar Bharati’s DD Free

Dish platform to an addressable system in a phased manner within a

specified timeframe, throughout the territory of India.

3.28 To enable addressable systems for DD Free Dish, Prasar Bharati needs

to replace the existing non-addressable STBs at consumer premises

with addressable STBs. This transition involves significant technical

upgrades, including the deployment of a CAS module for encryption,

SMS to maintain accurate records of subscribers. These enhancements

are essential to ensure that only authorized users can access the

content, thereby increasing security and enabling quality consumer

experience.

3.29 The Authority believes that MIB should provide Prasar Bharati with

adequate transition time to carry out the preparatory work necessary

for this significant upgrade. This transition period is critical to ensure

a smooth and effective migration process, minimizing disruptions for

the millions of households currently using DD Free Dish. Adequate time

would enable Prasar Bharati to address potential technical challenges,

educate consumers about the new system and ensure that all

subscribers are transitioned without loss of service.

3.30 After the acceptance of the recommendations and the administrative

approval by MIB, Prasar Bharati would be required to initiate transition

to the addressable system for DD Free Dish in the defined timeframe.

To enable this transition for the public service broadcaster, requisite

exemptions in TRAI’s Regulations will be examined and notified, if

required, to facilitate the continuation of free television services by the

public service broadcaster, after Government’s administrative/in-

principle decision on migrating DD Free Dish to an addressable system.

3.31 In view of the above, the Authority recommends that:

a. MIB should notify the upgradation of Prasar Bharati’s ‘DD Free

Dish’ platform to an addressable system in a phased manner

within a specified timeframe to ensure quality of viewing

experience, prevent unauthorized re-transmission of the

television channels to combat piracy and maintain the record

of subscribers.

b. Such notification by MIB should provide adequate transition

time to enable Prasar Bharati to carry out the preparatory work

for upgradation of its system and migration of the subscribers.

Public service broadcaster will be provided with the requisite

exemptions of TRAI Regulations, once such notification is

issued by MIB.

B2. Deployment of indigenous CAS, SMS and interoperable STBs

3.32 TRAI in its recently released Recommendations on ‘Inputs for

formulation of National Broadcasting Policy-2024’ dated 20

June

2024

has emphasized on promoting and adoption of indigenous

broadcasting technologies and equipment. It has been mentioned that

most of the broadcast equipment are not available in the Indian market

and are being imported. Also, Indian firms are not competitive on

account of pricing and quality. This makes reliance on other countries

for import of STBs, CAS and other broadcasting equipment. Therefore,

to reduce this dependency and bolster the broadcasting industry's

growth, it is imperative to invest in and develop indigenous

manufacturing capabilities for the broadcasting ecosystem.

https://trai.gov.in/sites/default/files/Recommendations_20062024.pdf

3.33 In line with the indigenous manufacturing of broadcasting equipment

and technologies, the sector is predominantly dependent upon imports

for the deployment of equipment in the distribution networks. The share

of locally manufactured equipment continues to remain insignificant.

These concerns become even more noteworthy while considering global

industry reports. The global broadcast equipment market

is expected

to reach around USD 6.7 billion by 2028 from USD 5.2 billion in 2023,

registering a Compound Annual Growth Rate (CAGR) of approximately

5.3% from 2023 to 2028.

3.34 It may be specified that during an interaction with C-DOT, it was

informed that C-DOT has developed the technologies for indigenous

products

for the broadcasting sector, including SMS, CAS and STBs

for OTT, DTH and other segments. Engaging C-DOT or any other Indian

organization to develop key technologies for DD Free Dish can save

costs, boost the local economy and reduce dependency on foreign

technologies. This approach would also support national initiatives like

‘Make in India’, promoting self-reliance and technological innovation.

3.35 Additionally, working with local organizations would lead to faster and

more efficient implementation of indigenous broadcasting technologies.

It would help to build a skilled workforce and enhance India's

technological capabilities. In this context, the Authority believes that

Prasar Bharati should consider deploying the C-DOT products in its

network. Additionally, the Government should facilitate the transfer of

these indigenous technologies/products developed by C-DOT to Indian

vendors. This initiative would promote the indigenization of

broadcasting equipment, making India more self-reliant and reducing

dependence on imported services.

3.36 The Authority in its Recommendations on ‘Inputs for formulation of

National Broadcasting Policy-2024’ dated 20.06.2024 has

recommended for ‘Mandating public service broadcaster to procure and

https://www.marketsandmarkets.com/Market-Reports/broadcast-equipment-market-

111738599.html

https://www.cdot.in/cdotweb/web/product_category.php?lang=en&catId=8

deploy indigenous broadcasting technologies and equipment in certain

proportion’. The Authority believes that Prasar Bharati should come

forward conducting suitable trials and deploying indigenous

broadcasting equipment manufactured by Indian vendors. This would

create a conducive environment, enabling private operators also to

utilize indigenous broadcasting equipment, thereby reducing

dependency on imports.

3.37 Further, the Authority is of the view that along with the promotion of

indigenous broadcasting equipment, this is the appropriate time to

implement interoperability of STBs. Although presently STBs in the

market use different compression techniques, coding techniques,

encryption system, middleware and operating system. It has been learnt

from C-DOT that its interoperable STB (CiSTB)

makes STBs

independent of service providers. It also addresses the issues related to

content security and can work in a non-interoperable mode as well.

3.38 In view of the above, the Authority recommends that Prasar Bharati

should engage C-DOT or any other Indian organization for utilizing

indigenous technologies for Conditional Access System (CAS),

Subscriber Management System (SMS) and interoperable Set-Top-

Box (STB) for adoption by ‘DD Free Dish’.

3.39 Referring to TRAI’s recommendations on ‘Interoperability of Set-Top

Box’ dated 10

April 2020

, the Authority recommended that ‘All the

Set-Top-Boxes in India must support technical interoperability in

principle, i.e. every STB provided to a consumer must be interoperable.’

Interoperability of STBs would overcome the manifold consequences of

non-interoperable STBs. For instance, non-interoperability restricts the

choice of the consumer. Any consumer desirous of changing the service

provider has to pay for the STB of the new service provider. This entails

additional cost, thereby becoming a deterrent for the consumer. Such

https://www.cdot.in/cdotweb/web/product_page.php?lang=en&catId=6&pId=33

https://trai.gov.in/sites/default/files/Recommendation_11042020.pdf

migration cost often leaves consumers stuck with their current service

provider, thereby infringing upon their freedom of choice.

3.40 Further, non-interoperable STBs that become inactive or remain idle for

a long time also have significant financial implications. Since these

inactive STBs cannot be used to receive services from other operators,

the investment in the STB gets wasted. Such non-reusable STB

contributes to electronic waste (e-waste). According to the Global E-

waste Monitor 2024

, India generated about 4100 billion kg of e-waste

in 2022 and ranked second among Asian countries after China in terms

of e-waste producing countries.

3.41 The Authority, therefore, is of the view that MIB should come out with

guidelines mandating all the service providers and Prasar Bharati to

start providing interoperable STBs to the consumers. Interoperability of

STBs empowers consumers to switch between different service

providers without purchasing a new STB, making it easier to choose the

best service for their needs. Additionally, this measure helps reduce e-

waste. The Authority is of the view that Prasar Bharati should act as a

catalyst in adopting interoperable STBs. Simultaneously, MIB may also

direct private DPOs also to start adopting and implementing

interoperable STBs.

3.42 Accordingly, the Authority reiterates that all the Set-Top-Boxes in

India must support technical interoperability in principle, i.e.

every STB provided to a consumer must be interoperable. The

Authority recommends that Prasar Bharati should adopt

interoperable STBs for ‘DD Free Dish’ for transitioning the entire

ecosystem from operator-based STBs to interoperable STBs to

empower consumers’ choice. MIB may also direct private

Distribution Platform Operator (DPOs) to adopt and implement

interoperable STBs.

https://ewastemonitor.info/wp-content/uploads/2024/03/GEM_2024_18-

03_web_page_per_page_web.pdf

B3. Conformity of CAS, SMS and STBs with Indian Standards

3.43 It may be noted that TRAI has designated Telecommunication

Engineering Centre (TEC) as the testing and certification agency for CAS

and SMS used for broadcasting and cable TV services as per Order

dated 20

September 2021

. Further, TRAI issued an Order on 9

August 2023

to all DPOs, mandating their deployed CAS and SMS

systems to undergo testing in accordance with the test guides provided

by TEC by accredited laboratories and subsequently certified by TEC.

The Authority is of the opinion that Prasar Bharati while deploying the

indigenous CAS and SMS should conform to the testing and

certification requirements, as notified by TEC.

3.44 Moreover, the Authority believes that the interoperable STBs should be

compliant with specified standards of the Bureau of Indian Standards

(BIS), or any other standard authorised by the Government. BIS

registration ensures quality, safety and reliability of products in

accordance with Indian Standards (IS). BIS registration ensures quality,

safety and reliability of products in accordance with Indian Standards.

The BIS registration under Compulsory Registration Scheme (CRS) was

introduced by the Ministry of Electronics and Information Technology

(MeitY) in 2012 for 15 product categories. The BIS-CRS registration

mainly covers products in IT, electronics and lighting categories.

3.45 In light of the above, the Authority recommends that the indigenous

CAS and SMS should conform to the testing and certification

requirements as notified by the Telecommunication Engineering

Centre (TEC). The STBs should be compliant with the specified

Bureau of Indian Standard (BIS) specifications, or any other

standard approved by any agency authorised by the Central

Government.

https://trai.gov.in/sites/default/files/Order_CAS_SMS_20092021.pdf

https://trai.gov.in/sites/default/files/Order_09082023_0.pdf

B4. Suggested transition for encryption and uplinking of television

channels

3.46 It needs to be emphasized that conversion from analog to DAS for the

DPOs in the private sector started in 2012 and was completed by March

2017, wherein cable operators made huge investments to implement

DAS to provide encrypted signals of TV channels through STB deployed

at the consumer premises. However, DD Free Dish still being a non-

addressable system, channels available at the DD Free Dish platform

are unencrypted.

3.47 As a first step, to address the issue of level playing field with private

television channels, TRAI in its recommendations on ‘Inputs for

formulation of National Broadcasting Policy-2024’ recommended that:

‘Enabling addressable systems for ‘DD Free Dish’ platform to maintain

subscribers’ detail, ensuring quality of service and preventing

unauthorized distribution of the content to address the issue of level

playing field particularly for the private television channels’.

3.48 The Authority believes that by leveraging the potential benefits of the

addressable system would enable Prasar Bharati to fulfil the mandate

of delivering quality content and services in public interest. Therefore,

DD Free Dish platform needs to be upgraded to addressable systems in

a time-bound manner with a defined sunset date, giving a reasonable

notice period, say until expiry of current agreement with the

broadcasters, to fulfil the existing contractual obligations. The process

of encryption of television channels may be initiated in a phased

manner, by prioritizing encryption of the television channels of the

private broadcasters in first place followed by the other television

channels of Doordarshan, educational and radio channels available on

DD Free Dish.

3.49 In view of the above, the Authority recommends that Prasar Bharati

should initially start the encryption of the television channels of

private broadcasters available at the ‘DD Free Dish’ headend, giving

a reasonable notice period to such broadcasters for meeting their

existing contractual obligations. Subsequently, all other television

channels of ‘DD Free Dish’ may also be transmitted in encrypted

form.

3.50 To upgrade the DD Free Dish platform to an addressable system, Prasar

Bharati needs to deploy CAS module sourced from Indian vendors,

featuring advanced encryption software at the DD Free Dish headend.

This CAS module, equipped with a sophisticated lock and key

arrangement for encryption, is essential to combat piracy and secure

content. The transition to an addressable system necessitates the

replacement of existing non-addressable STBs with new, addressable

ones. This significant upgrade will not only enhance security but also

enable precise tracking and management of subscriber data, thereby

allowing for improved service delivery and targeted content offerings.

3.51 To fulfil its mandate to inform, educate and entertain the masses, the

Authority advocates a phased approach to encrypt the feed at the DD

Free Dish headend:

i. In the first phase, the signals of all channels (presently 75) from

private broadcasters, including both pay and FTA channels, as well

as foreign channels (presently 3), should be encrypted at the DD

Free Dish headend, after giving a reasonable notice period to the

broadcasters, say until the expiry of their existing broadcasting

agreements. This encryption would help secure content and prevent

unauthorized access, ensuring that only legitimate subscribers can

view these channels.

ii. Meanwhile, the signals of educational channels (presently 51),

Doordarshan channels (presently 41, including the two channels of

Central Government which broadcasts the proceedings of the two

Houses of Indian Parliament and other public affairs programming)

and radio channels (presently 48) may continue to remain

unencrypted. Keeping these channels unencrypted ensures that the

consumers who have already invested in unencrypted STBs, retain

free and easy access to essential educational and public service

content until the reasonable lifespan of STBs, say four years.

However, after the specified timeframe all the DD channels should

be transmitted in encrypted form.

3.52 The Authority recognizes that during the transition to addressable

STBs, there would be a certain group of consumers who have recently

purchased the STBs and would not be willing to replace. For such

consumers, the Authority is of the view that they may continue to have

access to all 140 Government channels. Given the typical lifespan of a

STB as 4-5 years, the Authority believes that after a period of 4 years,

all non-addressable STBs in use should be replaced mandatorily.

3.53 The Authority is of the view that the sale of non-addressable STBs

should be prohibited in the market from 1

January 2025, in

consultation with MeitY, after arrangements for the provision of

addressable STBs are put in place by the public service broadcaster.

Accordingly, a prior notice should be issued to all the manufacturers

and sellers to cease the production and distribution of non-addressable

STBs.

3.54 Further, the Authority is of the view that the encryption process at the

DD Free Dish headend shall commence from 1

April 2025. This

timeline would provide Prasar Bharati with sufficient time to undertake

necessary preparations for the upgrade, including technical integration,

procurement of equipment and consumer education initiatives. This

strategic phased approach is crucial for the successful implementation

and sustainability of the upgraded DD Free Dish platform. Additionally,

this would ensure that consumers are not unduly burdened and there

is a smooth transition to addressable system.

3.55 Apropos to the above discussion, the Authority recommends that

with effect from 1

April 2025, encryption of the feed/transport

streams of the television channels at ‘DD Free Dish’ headend

should be done in the following manner:

a. Signals of permitted satellite television channels of the private

broadcasters available on the platform of ‘DD Free Dish’ should

be encrypted before uplinking.

b. Signals of other television channels including educational

channels of the Government, Doordarshan channels and radio

channels of Prasar Bharati may continue to be uplinked

unencrypted.

3.56 Further, the Authority recommends that:

a. Eventually all the television channels including the DD

channels, should be mandatorily encrypted before uplinking

from ‘DD Free Dish’ headend within a period of four (04) years

from the date notified for stopping sale of non-addressable

STBs.

b. The sale of non-addressable STBs should be prohibited in the

market from 1

January 2025, in consultation with MeitY, after

arrangements for the provision of addressable STBs are put in

place by the public service broadcaster.

B5. Introduction and distribution of indigenous addressable STBs in

the market for ‘DD Free Dish’

3.57 Presently, the non-addressable STBs of the DD Free Dish have very

basic functionality as compared with the addressable STBs utilized by

the DTH and cable operators. Recognizing the potential benefits of the

addressable STBs, the Authority believes that the existing non-

addressable STBs of the DD Free Dish needs to be upgraded to an

addressable STB within a defined time frame. Considering, the base

figure of 45-50 million STBs as per industry estimates, the Authority

believes that Prasar Bharati should authorize adequate number of

Indian STB manufacturers for manufacturing of addressable STBs.

These addressable STBs may be made available to the consumers

through the distribution network of such manufactures, and/or the

distributors authorized by Prasar Bharati for sales and aftersales

services such as installation, repair and maintenance of STBs for DD

Free Dish. This model will ensure a wide accessible distribution

network, with adequate competition in the market, making it easier for

consumers to install and obtain aftersales services such as installation,

repair and maintenance of their STBs from such authorized dealers.

3.58 The Authority believes that the introduction of these addressable STBs

from 01

January 2025 would ensure a timely transition while giving

Indian manufacturers adequate time for production and roll-out.

3.59 It may be mentioned here that TRAI in its Recommendations on ‘KYC of

DTH Set Top Boxes’ dated 24

October 2019

recommended the

process of KYC of DTH services. Accepting TRAI’s Recommendations,

MIB issued an Order on 15

February 2021, mentioning that the

Government has decided to implement customer identification for

providing DTH services. The Order directed all the DTH operators to

maintain KYC of STBs in a specified manner and to furnish compliance

report on quarterly basis. The same process may be followed by Prasar

Bharati through its authorized STB distributors.

3.60 Further, the Authority is of the view that the addressable STBs can be

made available or replaced for the underprivileged and marginalized

sections of the society at a subsidized cost or through appropriately

framed Direct Benefit Transfer (DBT) scheme, if the Government so

decides.

3.61 Based on the discussions above, the Authority recommends that

Prasar Bharati should authorize Indian STB manufacturers to

manufacture, and such indigenous interoperable addressable STBs

should be:

a. introduced in its market by not later than 1

January 2025.

b. made available to the consumers through the distribution

network of the manufacturers and/or distributors authorized

by Prasar Bharati for sales and aftersales services such as

installation, repair and maintenance.

c. provisioned for after fulfilling the KYC process, as notified by

MIB from time-to-time, for the records of Prasar Bharati.

d. made available for the underprivileged and marginalized

sections of the society at a subsidized cost or through

https://trai.gov.in/sites/default/files/Recommendation_24102019.pdf

appropriately framed Direct Benefit Transfer (DBT) scheme, if

the Government so decides.

B6. Awareness amongst consumers for uptake of addressable STBs

3.62 To make the public aware of the benefits of addressability as well as

various timelines decided by Prasar Bharati for transitioning DD Free

Dish to addressable system and replacement of subscribers’ STBs,

Prasar Bharati would be required to run consumer awareness

campaigns for the targeted subscribers and customised on the basis of

factors such as socio-economic background, language, region etc. Such

communication may be made through TV scrolls, advertisements in

print media such as newspaper or through other means, as deemed fit.

3.63 Besides spreading awareness about the benefits and necessity of

replacing old STBs with new addressable ones, the objectives of such

campaigns should focus on communicating the following information to

the consumers:

• Sale of non-addressable STBs will be stopped from 01

January

2025.

• Channels of private broadcasters will not be available in the non-

addressable STBs with effect from 1

April 2025.

• Educational channels, Doordarshan channels and radio channels

will continue to remain available in their existing non-addressable

STBs until 31

March 2029 through non-addressable STBs. After

that all the DD Channels will be available, only through addressable

STBs.

• Information about the arrangement made by Prasar Bharati for the

consumers to obtain the addressable STBs from the market through

the distribution network of its authorised manufacturers.

• Display list of manufacturers and distributors, and addresses of their

distribution outlets on its website to facilitate consumers to obtain

the addressable STBs and disseminate this information through

other means also.

3.64 Through these campaigns, consumers would become more aware of the

advantages and the improved functionalities of the new addressable

STBs. They would understand why it's important to upgrade their old

equipment. The campaigns might include information on the process

for obtaining a new one, and any potential costs or incentives associated

with the upgrade.

3.65 Overall, these campaigns would play a crucial role in educating

consumers, encouraging them to take action and ensure a smooth

transition to the new technology.

3.66 Accordingly, the Authority recommends that Prasar Bharati should

run awareness campaigns through TV scroll, advertisements in

print media, and/or other suitable means to inform the consumers

about various timelines for transitioning ‘DD Free Dish’ to

addressable system and replacement of their existing non-

addressable STB with the new addressable STB to continue

receiving the signals of the television channels of the private

broadcasters besides making them aware about the benefits of

using addressable STBs.

3.67 The Authority believes that the above-mentioned steps of introducing

addressability would yield several significant benefits. Firstly, it would

provide quality of viewing experience to the consumers. Encrypted

television signals will prevent their illegal re-transmission and hence

will keep a check on piracy. It would provide accurate data on the

number of consumers watching DD Free Dish and the locations of

installed STBs, including detailed insights into districts, regions and

states. This information would enable more precise and effective

content creation, tailored to the preferences and needs of different

audiences. Additionally, advertisers would be able to target their

advertisements more effectively, enhancing the relevance and impact of

their campaigns. Overall, addressability would lead to improved service

delivery, better audience engagement, combat piracy and increased

opportunities for targeted advertising.

CHAPTER IV

SUMMARY OF RECOMMENDATIONS

A. Listing of television channels in EPG

4.1 The Authority recommends that Ministry of Information and

Broadcasting (MIB) should seek information from broadcasters

about primary language of their television channel and sub-genre

of every non-news channel (as per Regulation 18(1) of

Interconnection Regulation 2017 (as amended) notified by the

Authority) while giving permission to each channel. The Authority

also recommends that the information so obtained may be

displayed on Broadcast Seva portal of MIB so as to enable the

distributors to arrange each channel in EPG accordingly.

4.2 The Authority further recommends that MIB may seek the above

information also for the existing permitted channels of

broadcasters and display the same on Broadcast Seva portal of MIB

so that the existing channels may also be arranged appropriately

in EPG by the distributors.

B. Addressability of DD Free Dish

B1. Upgradation of DD Free Dish to an addressable system

4.3 The Authority recommends that:

a. MIB should notify the upgradation of Prasar Bharati’s ‘DD Free

Dish’ platform to an addressable system in a phased manner

within a specified timeframe to ensure quality of viewing

experience, prevent unauthorized re-transmission of the

television channels to combat piracy and maintain the record

of subscribers.

b. Such notification by MIB should provide adequate transition

time to enable Prasar Bharati to carry out the preparatory work

for upgradation of its system and migration of the subscribers.

Public service broadcaster will be provided with the requisite

exemptions of TRAI Regulations, once such notification is

issued by MIB.

B2. Deployment of indigenous CAS, SMS and interoperable STB

4.4 The Authority recommends that Prasar Bharati should engage C-

DOT or any other Indian organization for utilizing indigenous

technologies for Conditional Access System (CAS), Subscriber

Management System (SMS) and interoperable Set-Top-Box (STB)

for adoption by ‘DD Free Dish’.

4.5 The Authority reiterates that all the Set-Top-Boxes in India must

support technical interoperability in principle, i.e. every STB

provided to a consumer must be interoperable. The Authority

recommends that Prasar Bharati should adopt interoperable STBs

for ‘DD Free Dish’ for transitioning the entire ecosystem from

operator-based STBs to interoperable STBs to empower

consumers’ choice. MIB may also direct private Distribution

Platform Operator (DPOs) to adopt and implement interoperable

STBs.

4.6 The Authority recommends that the indigenous CAS and SMS

should conform to the testing and certification requirements as

notified by the Telecommunication Engineering Centre (TEC). The

STBs should be compliant with the specified Bureau of Indian

Standard (BIS) specifications, or any other standard approved by

any agency authorised by the Central Government.

B3. Transmission of encrypted television channels by ‘DD Free Dish’

4.7 The Authority recommends that Prasar Bharati should initially

start the encryption of the television channels of private

broadcasters available at the ‘DD Free Dish’ headend, giving a

reasonable notice period to such broadcasters for meeting their

existing contractual obligations. Subsequently, all other television

channels of ‘DD Free Dish’ may also be transmitted in encrypted

form.

4.8 The Authority recommends that with effect from 1

April 2025,

encryption of the feed/transport streams of the television

channels at ‘DD Free Dish’ headend should be done in the

following manner:

a. Signals of permitted satellite television channels of the

private broadcasters available on the platform of ‘DD Free

Dish’ should be encrypted before uplinking.

b. Signals of other television channels including educational

channels of the Government, Doordarshan channels and radio

channels of Prasar Bharati may continue to be uplinked

unencrypted.

4.9 The Authority recommends that:

a. Eventually all the television channels including the DD

channels, should be mandatorily encrypted before uplinking

from ‘DD Free Dish’ headend within a period of four (04) years

from the date notified for stopping sale of non-addressable

STBs.

b. The sale of non-addressable STBs should be prohibited in the

market from 1

January 2025, in consultation with MeitY, after

arrangements for the provision of addressable STBs are put in

place by the public service broadcaster.

B4. Introduction and distribution of addressable STB in the market

4.10 The Authority recommends that Prasar Bharati should authorize

Indian STB manufacturers to manufacture, and such indigenous

interoperable addressable STBs should be:

a. introduced in its market by not later than 1

January 2025.

b. made available to the consumers through the distribution

network of the manufacturers and/or distributors authorized

by Prasar Bharati for sales and aftersales services such as

installation, repair and maintenance.

c. provisioned for after fulfilling the KYC process, as notified by

MIB from time-to-time, for the records of Prasar Bharati.

d. made available for the underprivileged and marginalized

sections of the society at a subsidized cost or through

appropriately framed Direct Benefit Transfer (DBT) scheme, if

the Government so decides.

4.11 The Authority recommends that Prasar Bharati should run

awareness campaigns through TV scroll, advertisements in print

media, and/or other suitable means to inform the consumers

about various timelines for transitioning ‘DD Free Dish’ to

addressable system and replacement of their existing non-

addressable STB with the new addressable STB to continue

receiving the signals of the television channels of the private

broadcasters besides making them aware about the benefits of

using addressable STBs.

List of Acronyms

Abbreviations

Description

BISAG

Bhaskaracharya National Institute for Space Application

and Geo-Informatics

BIS

Bureau of Indian Standards

CAS

Conditional Access System

CAGR

Compound Annual Growth Rate

C-DOT

Centre for Development of Telematics

CiSTB

C-DOT's Interoperable Set-Top-Box

CPE

Consumer Premise Equipment

CRS

Compulsory Registration Scheme

DAS

Digital Addressable System

DBT

Direct Benefit Transfer

DPO

Distribution Platform Operators

DTH

Direct-To-Home

EPG

Electronic Programme Guide

e-waste

Electronic waste

FTA

Free-To-Air

HPHT

High Power High Transmitter

Indian Standards

KYC

Know Your Customer

LCN

Logical Channel Number

MeitY

Ministry of Electronics and Information Technology

MIB

Ministry of Information and Broadcasting

MRP

Maximum Retail Price

OHD

Open House Discussion

RCU

Remote Control Unit

SMS

Subscriber Management System

STB

Set-Top-Box

TDSAT

Telecom Disputes Settlement and Appellate Tribunal

TEC

Telecommunication Engineering Centre

TRAI

Telecom Regulatory Authority of India

Annexure I

DD Free Dish LCN Lineup

Annexure II

Categorization of DD-Free Dish slots for e-Auctions

1. For MPEG-2 slots:

2. For MPEG-4 slots: Bidding in the e-auction of vacant MPEG-4 slots opens

to all genre (language) Channels without any bucket categorisation.