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Regulating OTT Services: What did OLX, Paytm and ShareChat say in their comments

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This report outlines which scores, monetary and social providers OLX, Paytm and ShareChat reported on TRAI's public consultation on the regulation of OTT providers. OTT suppliers have been shortened to OTT providers solely in the report. A few of these points have been edited and paraphrase.



Q1. What service (s) provided by OTT's service supplier (s) ought to be thought-about the identical or just like the providers provided by TSP? Proposals are required, appointing OTT providers with descriptions comparing them to providers offered by TSP


  • In accordance with the draft EU Digital Communications Code, both major and associated service suppliers use TSP's network infrastructure, however only vital OTT providers
  • Important OTT service providers ought to be thought-about the same / just like TSP providers as a result of they are substitutable and competing with them
  • It will be arbitrary and anti-competitive to mitigate vital and associated OTT providers, as virtually all OTT providers have some communication.


The next OTT service supplier providers could be thought-about the identical or just like the providers provided by TSP –

  1. Personal Messaging – Personal Messages
  2. Company Messages – Messages from Enterprise to Particular person
  3. Video


  • TSPs have scarce assets that make them remarkably distinctive for on-line communication platforms
  • The compatibility of some elements of providers provided by online providers doesn’t make them just like TSPs.

Question 2 : Are there any issues related to legal interception of OTT communications that must be resolved by national security or different security measures? Ought to the obligations of OTT's service providers and TSPs be separated?

OLX: No Answer


  • Because the OTT service provider has not detected any pretend news that spreads via its discussion board. Indian colleagues, it’s crucial that applicable provisions, reminiscent of these relevant to the TSP, additionally apply to OTT service suppliers (Article 69 of the IT Act authorizes the federal government to intercept, monitor or decrypt any pc repository).
  • National Security and Surveillance / Regulatory Control The Indian authorities should have absolute and unrestricted entry to Indian knowledge
  • Info saved outdoors India is open for attainable misuse. As most OTT service providers retain, course of and transfer info belonging to Indian residents or corporations in another country, it is troublesome for regulation enforcement authorities to research or collect proof in felony and tax matters.
  • OTT Providers must be approved to save lots of


  • The Consultation Doc assumes that an OTT vessel with the same providers as voice or textual content is just like TSP. This might be considerably just like a bicycle comparison on the bus. Though both present transport providers, their providers cannot be thought-about as comparable or substitutable.
  • As a subjective commonplace, the regulatory body would define the "substitutability" of the appliance, creating political uncertainty on a web-based platform that uses communication features. as a further function of its core performance (e.g., cost system chat methods). As well as, it could possibly make corporations run the danger of avoiding improvements in communications purposes in order to keep away from the danger of being categorised as OTT.
  • A number of nuances have to be thought-about to find out substitution and to find out substantial subjectivity to find out this, to make the OTT classification a challenging and unproductive effort

Q.three. Have regulatory or licensing imbalances influenced inflation in the telecommunication networks which might be needed occasionally to increase network capacity and upgrade know-how? If sure, how can OTT providers take part in funding in telecommunications networks?


  • TSPs invest in telecommunications infrastructure and use heavy license charges because they use a public resource spectrum.
  • OTTs function further providers to networks which are depending on possession and control of TSPs, and thus the consumption of OTT providers depends upon the agreement between the subscriber and the TSP.
  • Clients pay TSPs immediately for Internet bandwidth to make use of OTT providers, resulting in income income.
  • OTT service suppliers do not obtain direct income from using the network, and not often do shoppers pay OTT for using their providers.
  • A simple cost-benefit evaluation finds that TSPs have benefited most from investing in network capability extensions because they charge clients a daily direct subscription payment and revenue instantly from an increase in OTT service customers progress and knowledge calls

Paytm [19659003] The next rules ought to be imposed on OTT service providers

  • OTT providers ought to be subject to the IT regulation of 2000 for nationwide safety. / In regulatory oversight, the Indian authorities have to realize absolute and unrestricted access


  • It states that regulatory differences don’t essentially lead to regulatory imbalances.
  • As the ITU has said, the mere incontrovertible fact that business has a technology-driven business problem
  • The modifications in know-how will lead to a change in enterprise fashions, displaying that the rise of the first TSP knowledge in nations similar to India has increased.
  • Globally, researchers have proposed higher partnerships between OTT providers and TSPs to generate income.
  • Although community neutrality rules would exist, a few of the measures TSPs can implement are:
    • which generates new sources of revenue: creating new options corresponding to IPTV or new providers akin to cellular money
    • that promote the deployment of high bandwidth products: offering free entry to worthwhile purposes corresponding to gaming providers or video distribution environments.
  • For TSPs on network utilization, we advise:
    • The primary can be payments to TSP to hitch a competing community.
    • The congestion required by the session document is especially knowledge visitors paid by shoppers and which accounts for a big half of the present income of the TSPs

. the most important incentive to ensure quick connection availability

Q.4. Would interoperability of OTT providers, and also the interoperability of their providers with TSP providers, promote competitors and profit users? What measures could be taken to advertise such competitors, if any?


  • Because TSPs already own and management networks to which OTT purposes work, promoting interoperability might lead to TSP's anti-competitive practices.
  • TSPs can interact in discrimination based mostly on info providers to encourage their personal and owned OTT platforms, which might be contrary to internet neutrality.
  • When two totally different OTT providers enable interoperability, it is part of their contract agreement, which makes it attainable to do
  • Because a couple of major players dominate the TSP market, selling their interoperability with OTT might lead to an oligarchic, if not monopolistic and predatory pricing. OTT.
  • The identical does not apply to interoperability between OTT providers, which might profit the top consumer because of the quantity and versatility of OTT providers

Paytm: Yes

ShareChat [19659006] The web communications platform's funds might pose future competition risks referring to the lock-in of customers' on-line environments, in specific funds, financial providers and e-commerce

  • . Risks could possibly be better addressed by the Regulatory Authority (ie as an alternative of the Competition Authority)
  • Q.5. Are points associated to the authorized interception of OTT communications that have to be resolved via nationwide safety or different safety measures? Ought to the duties of OTT's service providers and TSPs be separated?


    • OTT platforms which might be absolutely compliant with applicable legal guidelines and laws don’t look like essential.
    • OTT's obligations and obligations for service suppliers and TSPs are separate and ought to be addressed by way of separate regulatory techniques
    • OTT's service suppliers do not use their personal network and do not lease network capability from the network operator. All issues that are not in pressure or are presently handled in present laws, akin to knowledge protection and privacy, also needs to be regulated separately by the TSPs and OTT.


    • Appointment of Native Officers, Establishment of Home Response Models, and All Social Media and OTT Communications Models in the Indian Market ought to require proactive use of know-how to satisfy nationwide standards.
    • Nevertheless, we ask that the regulatory obligations of the platforms be streamlined and restricted. The institution of various regulatory authorities and compliance with totally different laws would solely require compliance costs and would deliver the limited public coverage profit to the government as an entire.
    • The present regulatory framework and the reforms proposed by the federal government (lively monitoring and enforcement) ought to be enough to unravel these issues

    Q6. Ought to it’s potential for emergency providers to be out there by way of OTT platforms in accordance with the necessities imposed on telecom operators? Make ideas with reasoning

    OLX, Paytm, ShareChat: No Answer

    Q.7. Is there a degree enjoying area between OTT suppliers and TSPs that provide the same or comparable providers? In that case, should OTT providers be topic to regulatory or licensing rules in order to have a degree enjoying subject?


    • TSPs can take part in competing corporations with OTT.
    • Market dynamics are greatest qualified to find out the course of the OTT ecosystem, because area regulation and licensing laws can increase limitations to market entry for start-ups and SMEs


    • The TRAI session doc also states that each TSPs and OTTs are regulated equally in accordance with the IT Act 2000
    • ShareChat acknowledges that some non-resident community environments are usually not adequate. – Complies with Indian regulatory standards. Nevertheless, we consider that this can be better solved by reforming the precise regulation (in respect of middleman rules) and by enhancing cross-border regulation enforcement processes (corresponding to letters rogatory and mutual authorized assistance).

    Q8: a regulatory or license clause is proposed to be applied to OTT suppliers in response to Q.7, is the evaluate or redefinition of such provisions or permit circumstances in reference to OTT providers, or can they be utilized in this kind themselves? If a assessment or redefinition is proposed, the required modifications shall be proposed or proposed with justification.


    • We're not seeing any situations of licensing online environments.
    • We advocate that these models adjust to regulation enforcement requests resembling Indian-owned and domestic know-how corporations corresponding to Sharechat.

    Different Points Marked by ShareChat

    • Social Communications Platforms Present Vital Shopper and Monetary Advantages
    • Licensing of e-business could also be detrimental to the aim of self-starting local innovation financial system
    • costs
    • The aim of the laws must be to realize the professional political objectives of the federal government [19659091] Read what telecoms operators stated in their comments to TRAI