TRAI publishes audit manual for digital addressable systems of DPOs

MUMBAI: The Telecom Regulatory Authority of India (TRAI) has issued the Telecommunication (Broadcasting and Cable) Services Digital Addressable Systems Audit Manual.

Interconnection Regulations, 2017 provides for the audit initiated by the Distribution Platform Operator (DPO) vide sub Regulation (1) of Regulation 15 or by the Broadcaster vide sub Regulation (7) of Regulation 10 and sub-regulation (2) of Regulation 15.

Effective and factual Audit of the systems of distribution platform operator (DPO) will ensure that the equipment and the software (including the configuration of systems) comply with the extant regulatory framework.

According to TRAI, this audit manual addresses the issue of audit in terms of Regulations 10 and 15 of the Interconnection Regulations 2017.

It further stated that this audit manual may be reviewed periodically, owing to the technological/ techno-commercial changes, market development and changes in the systems. The Audit Manual is proposed as a guidance document for stakeholders.

The regulator also stated that this manual does not supersede any provisions of the extant regulations. In case of any discrepancy between the provision of Interconnection Regulations 2017, other extant Regulations or Tariff Order and the Audit Manual, the provisions as per the regulations/tariff orders shall prevail.

The audits provisioned under Interconnection Regulations 2017 are broadly divided into two categories (i) pre-signal or compliance audit and (ii) subscription audit.

The audit will be called Pre-signal audit if it is carried out before the content acquisition by the Distribution Platform Operator (DPO) from respective broadcaster otherwise it will be called as compliance audit. The authority noted that the pre-signal/compliance audit will be carried out as per Schedule III mentioned in the Interconnection Regulations 2017.

Regulation 15 of the Interconnection Regulations 2017 specifies that every distributor of television channels shall, once in a calendar year, cause audit of its subscriber management system, conditional access system and other related systems by an auditor to verify that the monthly subscription reports made available by the distributor to the broadcasters are complete, true and correct, and issue an audit report to this effect to each broadcaster with whom it has entered into an interconnection agreement.

“It may be noted that all the subscription report for each month with respect to each broadcaster with whom the distributor has signed an agreement will be necessarily required to be checked by the auditor. This audit is generally called subscription audit,” TRAI stated.

As per the Regulation, the DPO and broadcasters can get the audit conducted either by Broadcast Engineering Consultants India Limited (BECIL) or any other agency empanelled by TRAI.

The new framework envisages that the DPO gets its systems audited every year so as to assure the broadcasters that true subscription numbers are being reported.

In cases where a broadcaster is not satisfied with the outcomes of audit undertaken by the DPO, a countervailing provision empowers the broadcaster to initiate an audit. Considering the importance of audit to establish the trust-based regime, industry stakeholders suggested to provide an Audit Manual.

The audit manual has been prepared on the basis of the feedback of the committee constituted by the authority comprising of industry stakeholders. The committee prepared and submitted the draft audit manual to the authority.

The committee held several meetings in TRAI. These meetings were facilitated by the authority. After extensive deliberations, the industry reached consensus on most of the issues barring few issues and submitted a draft audit manual to the authority.

Based on the committee report and after considering all objections/representations, the Authority issued a consultation paper on ‘The Telecommunication (Broadcasting and Cable) Services Digital Addressable Systems Audit Manual on 29 March 2019. All the comments received in the consultation process including at the Open House Discussions, have been duly considered, TRAI stated.

Telecommunication (Broadcasting and Cable) Services Digital Addressable Systems Audit Manual

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