TRAI’s seventh amendment draft: Reshaping audit and compliance

The Telecom Regulatory Authority of India (TRAI) has presented a new amendment draft to tighten governance and transparency in the broadcasting and cable distribution ecosystem.

On 22 September 2025, the regulator issued the draft Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Seventh Amendment) Regulations, 2025. This draft follows TRAI’s consultation paper issued on 9 August 2024 on the audit provisions of addressable systems and the Digital Addressable System Audit Manual.

After incorporating stakeholder feedback, the draft amendments now seek public comments until 6 October 2025, with the regulations scheduled to come into effect from 1 April 2026.

Key reforms in the draft

Annual audit redefined

Regulation 15 is rewritten to mandate that all distributors of television channels (DPOs) conduct annual audits of their Subscriber Management Systems (SMS), Conditional Access Systems (CAS), and Digital Rights Management (DRM) setups. Unlike the earlier calendar-year cycle, the audit will now cover the preceding financial year (April–March). DPOs must share the certified report with broadcasters by 30 September each year.

Exemption for small DPOs

Considering the compliance burden on small operators, the draft exempts DPOs with 30,000 or fewer active subscribers (as of the last day of the previous financial year) from the mandatory audit requirement. This is expected to ease the cost pressures on regional cable operators while still keeping compliance oversight intact.

Stricter audit timelines and accountability

Should a DPO fail to submit its audit report by the deadline, broadcasters may initiate their own audit, at their own cost, to be completed within four months from 30 September. Moreover, broadcasters disputing an audit report must file objections with evidence within 30 days of receipt. The distributor must pass these objections to the auditor within 7 days, and the auditor must respond within 30 days.

Regulatory framework for infrastructure sharing

The draft mandates separate instances of SMS/CAS/DRM for each distributor using shared infrastructure, strict data segregation, and reconciliation capability.

On watermarking, the draft introduces clarity; the infrastructure provider will insert the watermark at the encoder, while the seeker may provide its logo through the set-top box or middleware. To avoid clutter, the regulation recommends that consumers ideally see only two visible logos, that of the broadcaster and the last-mile distributor.

Auditor certification and independence

Audits must be conducted only by TRAI-empanelled auditors, with Broadcast Engineering Consultants India Ltd. (BECIL) continuing as a nodal entity. Auditors are required to provide not just technical findings but also an independence certificate, strengthening the credibility of the compliance process.

The road ahead

With written comments due by 6 October 2025, TRAI has signalled its intent to finalise and notify the amendment by April 2026. The draft regulation reaffirms TRAI’s balancing act by reducing compliance stress for smaller players, strengthening audit credibility, and providing broadcasters with timely recourse to dispute audit outcomes.