How TRAI is moving from rulebook to rule-check, with DPO audits now leading to penalties

New Delhi: The Telecom Regulatory Authority of India (TRAI) is increasingly moving from issuing frameworks to pushing compliance on the ground, with distribution platform operators (DPOs) coming under sharper scrutiny over mandatory Digital Addressable System (DAS) audits and related disclosures.

TRAI’s FY25 annual report shows the regulator has already begun using enforcement levers built into the interconnection regime. 

It issued show-cause notices on May 15, 2024 to 31 DPOs for non-compliance with the mandatory annual DAS audit requirement under Regulation 15(1) of the 2017 Interconnection Regulations. 

The regulator also issued orders of financial disincentive on April 22, 2024 against three MSOs for non-compliance with Regulation 15(1), linked to audits for calendar years 2020–2022. 

In a further escalation, TRAI’s compliance push has continued into FY26. In an October 31, 2025 notice, the regulator pointed to “non-compliance” by certain DPOs on the annual audit requirement and sought explanations, warning of action under the regulations. 

From audit obligations to audit deadlines

TRAI’s annual report records that on August 21, 2024 it wrote to DPOs to complete the audit process, including the final auditor report, by December 31, 2024, to avoid financial disincentive under the audit-linked sub-regulation. 

This enforcement posture sits alongside TRAI’s broader attempt to tighten the compliance architecture around addressable systems. 

The report notes TRAI’s August 9, 2023 order directing DPOs to deploy new Conditional Access System (CAS) and Subscriber Management System (SMS) that are tested and certified by TEC (or another designated agency) from March 1, 2024, and to upgrade and certify existing systems by March 1, 2025. 

Compliance is also shifting to consumer-facing transparency

TRAI’s July 8, 2024 amendments in the broadcasting sector also signal a tilt towards compliance and enforcement, not just consultation. 

In the annual report’s summary of those changes, TRAI notes that charges for services such as installation and activation, visiting, relocation and temporary suspension were moved to forbearance, but with a rider: DPOs have to publish these charges for “clarity and transparency” to consumers. 

TRAI’s own press release on the July 2024 amendments similarly positions the changes as a compliance-and-transparency reset across interconnection and consumer protection rules. 

Policy review continues, but the tone has changed

Even while it continues to run consultations, TRAI has been signalling that enforcement gaps in distribution are now a priority area. The annual report lists TRAI’s August 9, 2024 consultation paper specifically on audit-related provisions of the interconnection regulations and the DAS audit manual, a sign that the regulator is also looking to strengthen the audit framework itself. 

Put together, the actions suggest TRAI is increasingly willing to move beyond compliance-by-advisory and use notices, deadlines and disincentives to pull DPOs into line, especially on audits and the integrity of addressable system reporting, which sits at the heart of broadcast distribution disputes.