Inside India’s broadcast regulation trap: The TRAI-DPO co-dependency

New Delhi: India’s television distribution business is shrinking, and the trend is now hard to dispute. Subscriber numbers are dropping quarter after quarter. Cable homes are steadily slipping away. DTH platforms are losing ground as more viewing shifts to digital screens.

What has not shrunk with the market is regulation. If anything, the paperwork around television has only grown. Consultation papers keep coming, draft amendments do the rounds, and compliance keeps getting thicker. 

From afar, it looks like a sector in motion. On the ground, the market’s core problems look much the same.

The heart of the contradiction is a structural co-dependency between the Telecom Regulatory Authority of India (TRAI) and the distribution intermediaries it regulates.

TRAI was set up under the TRAI Act to regulate telecom services, spectrum use and network carriage. Broadcasting was not its original brief.

Television distribution entered TRAI’s remit because cable operators, DTH platforms and MSOs depend on spectrum, satellites and signal carriage. Since spectrum allocation and network regulation sit within telecom, distribution came under the same umbrella.

That logic worked when television was expanding and distribution was growing. It becomes far messier when the market is shrinking.

A declining market that still resists consolidation

The latest numbers suggest the subscriber slide is structural, not seasonal. Large cable operators have lost hundreds of thousands of customers within a single quarter. DTH platforms have shed millions of paying homes over the past few years.

In most industries, such contraction forces a cleanup. Players merge, weak links break, and consolidation accelerates.

Television distribution has not followed that script.

The last mile remains fragmented. Thousands of local cable operators continue to control small neighbourhood pockets. Consolidation has been slow, and where it does happen, it is uneven.

In many parts of the system, staying small is not seen as a disadvantage. It is a survival tactic. Scale brings formalisation, audits and scrutiny. Remaining small keeps the business flexible, and often keeps the regulatory glare softer.

The co-dependency written into regulation

Under the TRAI Act, the regulator’s role in broadcasting is tied to overseeing service providers. In practice, that means distribution intermediaries: local cable operators, MSOs, DTH platforms and IPTV services.

If that intermediary layer shrinks sharply, through exits, mergers or consolidation, the regulator’s day-to-day footprint shrinks with it. There are fewer licences to manage, fewer compliance filings to track and fewer interconnection disputes to arbitrate.

Institutions respond to incentives, just like markets do. Preserving the intermediary layer also preserves regulatory relevance. Nobody says this out loud, but the system often behaves as if stability is preferable to disruption.

Audits as evidence of co-dependency

You can see this tension most clearly in the audit problem.

Audits are meant to verify subscriber numbers and settle revenue disputes. When audits are patchy, trust between broadcasters and distributors weakens, and every commercial negotiation becomes harder.

Broadcasters have repeatedly complained that distributors either delay audits or submit inconsistent numbers. TRAI itself has acknowledged the gap.

In a notice issued in 2025, TRAI recorded that several distribution platform operators had not conducted audits for the year and directed them to complete the process by a deadline, warning of financial disincentives.

At the same time, TRAI’s own annual reporting shows that hundreds of audits were conducted under the digitisation framework in FY 2023-24 through empanelled agencies. Both can be true. Work does happen, but compliance remains uneven.

That unevenness is also where the co-dependency shows up. Aggressive enforcement would hit a large chunk of intermediaries already under stress. But if that intermediary layer weakens further, the regulatory system around it also shrinks. The outcome is a familiar pattern: strong rules on paper, partial outcomes in practice.

Why TRAI’s role is now under review

This is also why the Ministry of Information and Broadcasting (MIB) is examining whether broadcasting should remain with TRAI at all. The ministry has formally proposed removing broadcasting from the telecom regulator’s remit.

Broadcasters argue that a telecom-first framework does not fit a content-led industry shaped by advertising cycles, audience behaviour and cultural considerations.

They also flag a regulatory imbalance. Linear television operates under caps, audits and tariff controls, while OTT platforms face far fewer restrictions.

If the proposal goes through, broadcasting would move fully under MIB. Supporters believe that would align regulation with sector realities and reduce overlapping controls.

More importantly, they argue, it could break the co-dependency that has trained India’s TV distribution system to cope with decline rather than confront it.

The system has learnt how to survive. What it has not learnt is how to change. Without structural clarity, it will keep functioning, but growth will remain out of reach.