TRAI proposes strict IPTV audit rules to tackle piracy and subscriber data gaps

Clearer data checks for IPTV

The Telecom Regulatory Authority of India (TRAI) has proposed a detailed audit framework for Internet Protocol Television (IPTV) systems, aiming to crack down on subscriber under-reporting and piracy.

The draft manual, prepared in collaboration with Broadcast Engineering Consultants India Limited (BECIL), sets out exactly how auditors should verify subscriber data and check content-security controls. It targets systems that use Digital Rights Management (DRM) to deliver television channels, giving broadcasters a clearer view of whether distributors are accurately reporting their viewer numbers.

TRAI introduced these security and subscriber requirements, known as Schedule X, in 2023. However, the regulator’s existing audit manual did not include a step-by-step process for checking compliance. This new draft aims to fill that gap. Stakeholders have until 30 October to submit their comments.

Strict thresholds for subscriber data

Under the proposed rules, auditors will have to randomly select 20% of the weeks in an audit period, ensuring they cover at least one week from every month. They will then compare the distributor's monthly subscriber reports against raw data from its subscriber management system (SMS) and DRM system.

The threshold for errors is low. If an auditor finds a discrepancy of more than 1% in the monthly subscriber report for any à-la-carte channel or package during the sampled weeks, they must audit the entire period for that channel or package. Additionally, if the total variance in the monthly report exceeds 0.5%, the distributor will be required to notify the broadcaster so previous invoices can be adjusted.

Auditors will also check subscriber numbers on five random dates during the audit period. If they find a variance of more than 15% between the active customer data on a specific date and the wider audit period records, they must flag this to the broadcaster. They are also tasked with ensuring no undeclared parallel SMS or DRM systems are operating in the background. Broadcasters will be allowed to send one representative to observe the audit.

Tougher controls on digital piracy

Beyond subscriber numbers, the draft tightens the screws on piracy. It mandates that DRM systems must support visible, covert, and targeted fingerprinting, as well as forensic watermarking down to the individual set-top box or customer account. This fingerprinting must run at least once every 10 minutes, all day, every day.

The draft also requires distributors to restrict content sharing, mirroring, and, where technically possible, screenshots or screen recordings. Systems must block delivery to IP addresses outside India and screen out proxy servers or VPNs. For app-based IPTV, the DRM must be able to blacklist a user's registered mobile number or email address if piracy is detected.

Under existing rules, if a distributor's system is found to be non-compliant, broadcasters have the right to cut off their television signals after giving three weeks' written notice. TRAI has clarified that this new manual is a guide and does not override existing interconnection regulations.