BMI Exclusive: AIDCF urges I&B Ministry to drop proviso on landing pages

New Delhi: The All India Digital Cable Federation on Friday opposed the government’s proposal to exclude landing page viewership from television rating measurement, calling the move “neither technically justified nor operationally feasible” in a detailed response accessed exclusively by BestMediaInfo.

While supporting most of the draft amendments to the TRP policy guidelines, AIDCF told the Ministry of Information & Broadcasting that the landing page is a legitimate part of the viewing journey in digital TV homes and cannot be treated as “non-viewership”.

“The Landing Page, by design, is the first channel or stream that a viewer encounters upon switching on the television set-top box. In most Indian households, this is a legitimate and unavoidable part of the viewer’s experience,” AIDCF said, adding that “treating it as ‘non-viewership’ does not reflect actual consumer behaviour”.

According to the federation, removing landing page impressions from ratings would “distort the integrity of television audience measurement, reduce transparency, and unfairly penalise broadcasters and Multi-System Operators (MSOs).”

AIDCF submitted its comments on the draft amendments to the “Policy Guidelines for Television Rating Agencies in India” notified by the Ministry on November 6, 2025.

AIDCF describes the landing page as “an integral part of how television viewing begins in a digital household”, arguing that when a subscriber switches on the TV, the first channel delivers both content and advertising and that whether viewers stay or move away is a function of engagement, not legitimacy.

“Thus, landing exposure is real viewership,” the cable body said, pointing out that under the current BARC framework “every tuning event, including landing-page exposure, is recorded with dwell time”, with filters and audits already applied to prevent distortion and detect abnormal patterns.

On that basis, AIDCF has told the Ministry that there is already “a functional distinction between legitimate viewership and passive exposure without excluding an entire class of impressions”, and that viewers retain full discretion to continue watching or change channels. 

Excluding landing-page viewing, it argues, would amount to ignoring exposure that is visible and impactful, comparable to pretending that a reader does not see a front-page advertisement in a newspaper or a shopper does not notice an eye-level product in a store.

Responding to long-running criticism that landing-page placements inflate ratings, AIDCF has called those claims “overstated” and “an over-simplification”. 

It says incremental exposure is not unique to one or two channels and that any channel occupying landing or default positions may see higher sampling. 

Channels that sustain leadership, the federation has argued, typically combine distribution advantages “including but not limited to landing”, programming investment, brand strength and promotion, and that “landing exposure alone rarely explains long-term leadership”.

If gaming or misuse is detected, the federation has recommended detection and penalisation of manipulative patterns such as automated redirects or artificially generated boot events rather than removing an entire class of impressions from the measurement universe. 

It also warned that blanket exclusion “can disadvantage certain genres unfairly”, particularly news and regional channels that benefit from default discovery when viewers switch on to check headlines or updates.

To underline its argument, AIDCF has drawn analogies from print, retail and online platforms, noting that newspapers sell front-page jackets, retailers sell premium shelf space, and digital platforms sell sponsored listings, yet all such exposures and resulting consumption are counted in measurement.

On international benchmarks, AIDCF has told the Ministry that “no international regulator has introduced a rule to exclude default or landing exposures from measurement” and that India’s proposed move “would therefore be unprecedented and could isolate Indian TRP methodology from global best practices”.

In its recommendations, the federation “strongly” requested the Ministry not to proceed with the proposed proviso in Clause 5.5.1 on excluding landing page ratings and to “maintain inclusion of landing-page viewership within TRP data”. 

It stressed that its intent “is not to defend misuse” but to ensure that “legitimate and measurable exposure such as landing page viewership continues to be captured fairly within India’s television measurement framework”.

AIDCF backs most changes, flags concerns on Connected TV and panel size

At the same time, AIDCF has told the Ministry that it supports a majority of the proposed changes in the draft policy. 

It welcomed the substitution of the Companies Act 2013 in place of the 1956 Act, the strengthening of conflict-of-interest and cross-holding clauses to keep rating agencies independent of broadcasters, and the reduction in the minimum net worth requirement for rating agencies from Rs 20 crore to Rs 5 crore.

On Clause 5.2.1, dealing with Connected TV, the federation has said it agrees with the principle that ratings should be technologically neutral and capture viewing across platforms.

However, it has warned that explicitly recognising “Connected TV” in the policy, when many such services are not licensed under the existing broadcasting framework, could be misused as a de facto stamp of approval.

AIDCF pointed to Free Ad-Supported Streaming Television (FAST) services embedded in Connected TV devices, alleging that some of these are offering pay TV channels as free-to-air in contravention of the tariff order and uplinking-downlinking guidelines, and that certain channels being transmitted are not even licensed.

It therefore requested that the words “Connected TV” be deleted from Clause 5.2.1 until a unified licensing and regulatory framework is created for FAST TV, digital DPOs and online, internet-based content applications.

On panel size (Clause 5.3.5), AIDCF argued that the proposed sample of 1.2 lakh homes is inadequate for 210 million TV households.

It recommended that the panel size be raised to 5 lakh homes to make ratings more credible, capture true performance across markets and reduce the ability of “unscrupulous stakeholders” to influence data.

Call to include platform services and ground-based channels

In a separate section, AIDCF has reiterated an earlier request that “platform services” and “ground-based channels” run by distributors be brought within the TRP measurement framework alongside linear TV channels and Connected TV.

The federation has said it is “surprised” that the draft proposes to include Connected TV, which is not yet registered or licensed, while ignoring platform channels that are registered and offer a mix of local news and information, regional movies and music, religious content and other formats to large rural and urban audiences.

AIDCF argued that these services have significant reach across geographies and that “a truly democratic audience viewership would be incomplete without inclusion of viewership patterns for platform services and ground-based channels”.

It recalled that prior to BARC, TAM Media Research reported platform services as a distinct category, capturing their contribution, and that the shift to a single consolidated BARC currency has “inadvertently sidelined the visibility of platform services despite their continued relevance and reach”.

The body urged the Ministry to explicitly include platform services and ground-based channels in the TRP framework so that ratings reflect “India’s true viewership, especially in semi-urban and rural areas where these channels remain the primary source of information and entertainment”.

In its closing remarks, AIDCF requested the Ministry to reconsider the proposed landing-page exclusion and to incorporate its suggestions on Connected TV, panel size and platform services “during finalisation of the new TRP framework”, while reiterating its support for tighter conflict-of-interest safeguards and broader, technology-neutral measurement.