TRAI notifies new broadcasting audit rules, tightens timelines and curbs repeat audits

New Delhi: The Telecom Regulatory Authority of India (TRAI) has notified the Telecommunication (Broadcasting and Cable) Services Interconnection (Addressable Systems) (Seventh Amendment) Regulations, 2026, tightening audit timelines, limiting repeat audits, easing compliance for small distributors, and laying down clearer rules for audit escalation and infrastructure sharing.

The amendments mandate annual financial-year audits with a fixed September deadline, allow broadcaster presence during audits, restrict re-audits to regulator-approved cases, and impose sharper accountability on both auditors and distributors.

The changes represent one of the most substantive revisions to the broadcasting audit framework since the Interconnection Regulations were first introduced in 2017. 

TRAI has sought to address persistent industry complaints around overlapping audits, delayed reports, rising compliance costs, and weakening trust in the audit mechanism that underpins subscriber reporting and revenue settlements between broadcasters and distributors.

Shift to financial-year audits

A central feature of the new framework is the shift to audits based on the financial year. Distributors are now required to get their addressable systems, including subscriber management systems (SMS), conditional access systems (CAS) and digital rights management (DRM) platforms, audited for the preceding financial year and to share the complete audit report, along with annexures, with all connected broadcasters by 30 September each year. 

By aligning technical audits with the financial accounting cycle, the regulator aims to reduce prolonged reconciliation exercises and bring faster closure to billing disputes.

Tighter controls on repeat audits

To curb the problem of repetitive audits, the regulations introduce a structured audit escalation process. Broadcasters are permitted to depute one representative to attend audits conducted by TRAI-empanelled auditors. 

While the representative has no authority to influence the audit, their presence is intended to improve transparency during verification and reduce disagreements after the audit is completed.

If broadcasters identify discrepancies or inadequacies in an audit report, they must first seek clarifications from the auditor through the distributor. Auditors are required to respond within prescribed timelines. 

Only if the broadcaster remains dissatisfied after this stage can it approach TRAI for approval to conduct a fresh audit, which must be carried out at the broadcaster’s own cost. TRAI has framed this regulator-gated re-audit mechanism as a check against routine or speculative audits, while preserving a path for addressing material errors.

Enforcing audit timelines

The amendments also tighten compliance on audit timelines. If a distributor fails to provide the audit report by September 30, broadcasters are explicitly allowed to initiate an audit of that distributor. This provision is aimed at preventing delays that have previously allowed audits to remain incomplete for extended periods, undermining the credibility of subscriber data.

Relief for small distributors

Recognising the burden of mandatory audits on smaller operators, TRAI has introduced a threshold-based relaxation. Distributors with fewer than 30,000 subscribers are no longer required to conduct annual audits at their own cost. 

However, broadcasters retain the right to audit such distributors at the broadcaster’s expense. The regulator has positioned this change as a proportional compliance measure that reduces costs for small players without diluting oversight.

Clearer rules for infrastructure sharing

Infrastructure sharing, which has expanded across cable, DTH and headend-in-the-sky (HITS) platforms, is addressed through clearer audit and system requirements. Where SMS, CAS or DRM systems are shared, the regulations require each distributor to independently meet all technical and regulatory conditions. 

Separate system instances must be created to ensure data segregation and enable entity-wise reconciliation during audits. The aim is to eliminate ambiguity over subscriber attribution and accountability in shared infrastructure arrangements.

Watermarking and viewer experience

The amendments also clarify watermarking obligations in shared setups. Infrastructure providers must insert network logo watermarking for all pay channels at the encoder level, while distributors using the shared infrastructure must provide their own network logos through set-top boxes or middleware. 

To protect viewer experience, TRAI has advised that the number of visible logos should preferably be limited to two.

Strengthening auditor accountability

Underlying the revised framework is a push to strengthen auditor accountability. TRAI has already tightened eligibility, experience and independence requirements through a separate empanelment process for auditors. 

Auditors are now required to certify their independence and compliance with regulatory standards, reinforcing the regulator’s view that a single, credible annual audit should normally suffice and that repeat audits should be the exception rather than the rule.

The regulatory overhaul follows a prolonged consultation process that began in August 2024 and included written stakeholder comments, counter-comments and an open house discussion. 

TRAI has argued that the amendments respond directly to industry feedback and address an urgent need to streamline audits without weakening regulatory oversight.

With the Seventh Amendment Regulations set to come into force on April 1, 2026, the focus will shift to implementation and whether the revised audit framework delivers the intended gains in timeliness, accountability and regulatory certainty across the broadcasting value chain.