TRAI is proposing a dedicated audit framework to strengthen content security, subscriber tracking and regulatory compliance for Internet Protocol Television (IPTV) services. The draft framework, issued on October 9, also brings software applications that perform set-top box functions under the proposed audit process while maintaining a clear technical distinction between IPTV and over-the-top (OTT) services.
Under the draft manual, a software application installed on a consumer device can be treated as a “unique consumer subscription” if it performs functions such as content decryption, decoding and Digital Rights Management (DRM) licence evaluation. This would bring app-based IPTV access within the proposed audit framework.
The Telecom Regulatory Authority of India (TRAI) has proposed specific checks for hybrid set-top boxes, which support both IPTV and OTT services. The DRM system must prevent OTT applications or browsers from accessing linear television channels provided by a distribution platform operator. Similarly, IPTV DRM systems must not access channels delivered through OTT platforms.
Although IPTV and OTT services may operate on the same device, their delivery systems must remain technically separate.
The draft also requires IPTV-based linear television to operate within a closed network. Auditors may connect IPTV applications, set-top boxes or user devices to another Wi-Fi network or mobile hotspot to verify whether television services remain accessible outside the designated network. The DRM system must prevent linear television channels from being delivered over the internet.
Software vendors providing app-based IPTV systems will also need security audit testing certificates from agencies empanelled by CERT-In. The proposed audits will examine DRM and Subscriber Management System (SMS) integration, subscriber activation and deactivation, fingerprinting, content protection and subscriber records.
TRAI has outlined several anti-piracy measures. DRM systems must restrict content sharing, forwarding and mirroring, prevent screenshots and screen recording where technically feasible, and limit access to authorised devices.
The framework also proposes IP-based restrictions to prevent television channels from being delivered to IP addresses outside India. Systems must also identify and block anonymising or spoofed proxy connections.
Fingerprinting requirements form another key part of the draft. DRM systems must support visible and covert fingerprinting, global and targeted fingerprinting, and forensic watermarking at the set-top box or unique-consumer-subscription level.
The systems must be capable of running fingerprinting at least once every 10 minutes, continuously throughout the year. Broadcasters must also be able to request access to fingerprinting schedules.
The proposed framework builds on Schedule X of the Interconnection Regulations, introduced by TRAI in September 2023, which established DRM requirements primarily for IPTV-based distribution. The new document focuses on auditing compliance with these provisions.
TRAI stated that its Digital Addressable Systems Audit Manual, issued in March 2026, covers Conditional Access Systems (CAS), SMS and set-top box-based addressable systems but lacks detailed, clause-wise audit procedures for Schedule X.
Prepared in consultation with BECIL, the new draft aims to address this gap. TRAI has invited stakeholder comments until October 30.
The regulator has clarified that the audit manual will serve as a guidance document and will not override existing regulations or tariff orders.
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