TRAI Consultation Paper on Regulatory Framework for Application-Based Linear Television Distribution (ALTD) Services (Including Free Ad-Supported Streaming Television (FAST) Services)

by Anushree Rauta (Equity Partner – Head Media & Entertainment and Gaming Practice), Umang Sheth (Principal Associate) and Shilpi Tripathi (Associate Trainee)

1. Purpose of This Note

On 6th April 2026, TRAI released Consultation Paper No. 02/2026¹ titled ‘Formulation of a Regulatory Framework for Application-based Linear Television Distribution (“ALTD“) Services (Including Free Ad-Supported Streaming Television (“FAST“) Services)’. This note is for stakeholders operating or connected with ALTD/FAST services in India, of what the consultation paper says, what questions TRAI is asking, and what the TRAI’s direction of thinking appears to be.

This is not a note about existing binding regulations. It is a summary of a public consultation. TRAI is in the process of gathering industry views. No new compliance obligations have been created yet. The note is intended to help business owners understand the regulatory landscape so they can decide whether to file comments with TRAI by 4th May 2026.

2. Background: Why Is TRAI Examining This Sector?

MIB sent a formal reference to TRAI on 15 December 2025,² asking TRAI to examine and recommend a regulatory framework for FAST services with four stated objectives: recommend a regulatory framework for FAST services, ensuring parity, content accountability, and consumer protection.

The MIB reference was prompted by representations from the All-India Digital Cable Federation (AIDCF) and Multi-System Operator (MSO) associations, who complained that FAST platforms operate as effective television distributors, delivering scheduled, linear TV channels to consumers but without the licensing, content compliance or consumer protection obligations applicable to cable TV, DTH, HITS and IPTV operators.

TRAI had itself flagged this issue in two earlier sets of recommendations, its ‘GBB Recommendations dated 15 January 2025’ and ‘Authorisation Recommendations dated 21 February 2025’ where it noted that FAST services perform functions similar to a licensed Distribution Platform Operator (DPO) but operate without regulatory oversight, and recommended that a separate authorisation for FAST channel distribution be considered.

3. Market Context³

FAST Services revenue in India projected at USD 63.69 million (approx. INR 590 crore) in 2023, estimated to reach USD 104.10 million (approx. INR 965 crore) by 2027
India had 116.4 million FAST service users in 2023; user base projected to reach 148.6 million by 2027
India’s Connected TV (CTV) audience base grew 85% in one year from 69.7 million (2024) to 129.2 million (2025).
Total internet subscribers crossed 1 billion as of November 2025. Data costs have fallen from ₹269/GB in 2014 to roughly ₹8–10/GB in 2025–26.
The conventional TV ecosystem comprises 300+ broadcasters, 774 registered MSOs, 1 HITS operator, 4 pay DTH operators, and 70+ IPTV providers.

4. What Are ALTD and FAST Services?

The consultation paper introduces the term ‘Application-based Linear Television Distribution (ALTD) Services’ as its umbrella term. ALTD covers all application providers that distribute scheduled, linear television channels to consumers, whether through:

pre-installed applications on smart television sets and other connected devices;
downloadable mobile or smart TV applications; or
web-based applications accessible through internet browsers.⁴

FAST Services are a subset of ALTD, specifically, services that deliver linear TV channels over the internet free of subscription charge, funded by advertising. ALTD is the broader term adopted by TRAI because some such services may be bundled within subscription packages or may evolve into paid offerings in the future.

4.1 Four Business Models Identified by TRAI

Based on stakeholder inputs already received, the consultation paper identifies four existing business models in the ALTD/FAST ecosystem:

Model	Description	Relevance / Concern Noted
Model I	TV manufacturer operates its own FAST platform pre-installed on its smart TVs (proprietary OS)	Manufacturer carries both responsibility and self-regulatory framework; 150+ channels reported
Model II	FAST platform operated by an overseas affiliate of an Indian entity; content managed by a third-party aggregator	Compliance managed overseas; Indian entity does not monitor content; grievances redirected abroad
Model III	Android-based OS provider powers FAST services across 300+ TV brands; content via its proprietary app store	Acts as intermediary; limited direct content control; no content archiving maintained
Model IV	FAST services via websites/apps hosting channels from multiple countries, some without MIB downlinking permission	MSO association flagged this as violation of Downlinking Guidelines 2022

5. Regulatory Gaps That Prompted This Consultation

The consultation paper is candid about why regulatory intervention is being considered. The following are the key gaps identified:

Content/Licensing Gaps: MSO and cable industry representations to MIB submitted that FAST services are being offered in violation of the Policy Guidelines for Uplinking and Downlinking of Television Channels in India, 2022, which require MIB permission before any TV channel is made available for public viewing in India.⁵
Regulatory Asymmetry: FAST platforms distribute the same live, scheduled television channels as cable, DTH, HITS and IPTV operators, but without equivalent licensing, content compliance (Programme Code and Advertising Code) or consumer protection obligations, creating an uneven playing field.⁶
Tariff/Pricing Distortion: Pay television channels that are subscription-based on conventional platforms, are reportedly available free of charge on certain ALTD/FAST platforms, potentially violating the TRAI Tariff Order, 2017 (as amended).⁷
Accountability Vacuum: With multiple entities involved (TV manufacturers, OS providers, app developers, overseas affiliates, content aggregators), it is currently unclear who bears regulatory responsibility when content violations or consumer issues arise.⁸
Audience Measurement Gap: FAST platform viewership is not captured in the television ratings/audience measurement system (currently managed by BARC), leading to incomplete market data for the industry.⁹

6. Questions TRAI Is Asking: A Summary

Chapter II of the Consultation Paper poses specific questions across eight thematic areas. These are questions for stakeholder input, they are not decisions.

6.1 Definition and Scope of ALTD Services¹⁰

TRAI observes that ALTD/FAST services are not explicitly defined in existing Indian broadcasting law, though the existing definition of ‘Distribution Service Provider’ is broad enough to potentially include them. TRAI refers to how UK (OfCom), Canada (CRTC), Australia (ACMA) and Italy (AGCOM) have approached definitions. TRAI asks:

What should be the appropriate definition and scope of ‘ALTD Services’ in the Indian broadcasting context, taking into account international terminologies?

6.2 Who Should Be the Primary Responsible Entity?¹¹

The ALTD ecosystem involves TV manufacturers, OS providers, application providers, content aggregators and overseas entities. TRAI’s preliminary view is that the application provider appears to play the most central role in aggregating and distributing channels. TRAI asks:

Should the Application Provider be designated as the primary stakeholder responsible for obtaining authorisation for ALTD Services? If not, who should be?

6.3 Authorisation Framework for ALTD Operators¹²

This is the most detailed section of the consultation, covering terms and conditions for a possible authorisation regime. TRAI notes that all entities currently distributing linear TV in India (DTH, HITS, MSO, IPTV) are required to be authorised or permitted by MIB. TRAI poses multiple questions on:

Eligibility & Authorisation: Whether a formal authorisation/registration framework should apply to ALTD service providers, akin to the existing frameworks for DTH/HITS/IPTV/Cable services.
Terms & Conditions: What should be the conditions for grant of authorisation including eligibility, financial net worth, nationality requirements, rollout obligations, and applicable fee structures.
Foreign Entities: Whether foreign/overseas entities operating ALTD services targeting Indian consumers should be required to have a local Indian presence and comply with Indian laws.
Infrastructure Sharing: Whether infrastructure sharing obligations should apply to ALTD service providers.

Note: Italy’s AGCOM issued the first two FAST channel authorisations on 19 March 2025, under a model where each individual FAST channel must obtain authorisation based on its programming schedule. TRAI references this as one possible model.

6.4 Television Channels on ALTD Platforms¹³

TRAI examines what obligations should apply to the television channels carried on ALTD platforms, and what obligations should apply to broadcasters, content aggregators and others who place channels on these platforms. Key questions include:

Channel Permissions: Whether ALTD platforms should be permitted to carry only channels that have valid MIB uplinking/downlinking permissions under the Policy Guidelines for Uplinking and Downlinking of Television Channels in India, 2022.
App Certification: Whether a certification mechanism should be required so that TV manufacturers and app store operators allow only MIB-authorised ALTD applications (pre-installed or downloadable).
Broadcaster Obligations: What obligations should apply to broadcasters and content aggregators in respect of channels they place on ALTD platforms.

6.5 Pay TV Channels Available Free on ALTD Platforms¹⁴

TRAI flags industry concern that pay television channels which are subscription-based on DTH and cable, are being offered free of charge on FAST platforms. This may distort market dynamics and potentially violate TRAI’s Tariff Order, 2017. TRAI is seeking stakeholder views:

On how this should be addressed, for example, whether pay channels should be prohibited from being distributed free on ALTD platforms?

6.6 Consumer Protection¹⁵

TRAI seeks views on what consumer protection obligations should apply to ALTD service providers. Topics under consideration include grievance redressal mechanisms, transparency of channel listings, quality of service standards, and what remedies should be available to consumers.

6.7 Audience Measurement¹⁶

TRAI proposes that ALTD/FAST viewership data should be incorporated into the existing television audience measurement framework. Currently, FAST platform viewership is not captured in ratings systems such as BARC. The questions cover how this integration should be structured and who should bear the associated costs.

6.8 Future Considerations¹⁷

TRAI acknowledges that ALTD services are evolving. The consultation asks about the regulatory treatment of hybrid models where platforms may transition from free to subscription-based or introduce ancillary paid services. It also asks about Quality of Service (QoS) standards, applicability of interconnection regulations, and catch-up/on-demand content offered alongside live linear TV.

7. What Stakeholder Should Be Aware Of (Without Prejudging the Outcome)

While this consultation does not create binding obligations, it gives a clear signal of regulatory intent. Stakeholders in the ALTD/FAST sectors should be aware of the following:

Regulatory Direction: TRAI at MIB’s request is examining and bringing ALTD/FAST services within a formal authorisation framework comparable to cable, DTH and IPTV.
Existing Legal Framework: MSO associations have explicitly stated to MIB that FAST services carrying channels without MIB downlinking permission may already be in violation of existing downlinking guidelines. Business owners carrying channels without valid MIB permissions may face risk under the current framework, independent of this consultation.
Business Model Risk: Business owners falling in Model II or Model IV (overseas-operated platforms, or platforms carrying unauthorised channels) as mentioned above, face the greatest regulatory uncertainty under the issues being examined.
Participation Opportunity: The consultation is a meaningful opportunity to shape the final regulatory framework. Filing a well-reasoned submission can influence the outcome on key issues such as, who is the primary responsible entity; fee structures; foreign entity requirements; and app certification rules.

8. How to Participate

Business owners and other stakeholders may file written comments with TRAI by 4th May 2026 and counter-comments by 18th May 2026:

Email

To DR. Deepali Sharma, Advisor (B&CS), Telecom Regulatory Authority of India

Email Id: advbcs-2@trai.gov.in and jtadvisor-bcs@trai.gov.in

Full Paper

http://www.trai.gov.in/sites/default/files/2026-04/CP_06042026.pdf

TRAI Website

www.trai.gov.in

Comments and counter-comments will be posted publicly on TRAI’s website. Stakeholders who wish to keep their commercial or technical details confidential should take care to segregate sensitive information or consult counsel before filing.

IMPORTANT NOTE: What this consultation paper does not prescribe compliance obligations, but asks for what framework to apply. No compliance checklist has been issued by TRAI. The final framework depends on: (a) stakeholder inputs; (b) TRAI’s recommendations to the Government; and (c) Government actions on those recommendations.

Footnote

¹ TRAI released Consultation Paper No. 02/2026 – http://www.trai.gov.in/sites/default/files/2026-04/CP_06042026.pdf
² MIB reference dated 15th December 2025 under section 11(1)(a) of the TRAI Act, 1997; reproduced under para 1.1 and 1.2 of the Consultation paper.
³ Market Insights as cited in the Consultation Paper – Page 22 onwards
⁴ Consultation Paper, Chapter II, Section A, Para 2.2 and Question 1 (page 31)
⁵ Consultation Paper. Chapter II. Section B. paras 2.13–2.16 and Question 2 (page 33)
⁶ Consultation Paper. Chapter II, Section C. para 2.17. The four permitted distribution platforms are DTH, HITS, IPTV and Cable Services through MSOS/LCOs (para 2.18)
⁷ Chapter II. Section D (television channel obligations. Questions 16–20) and Section E (pay channels free on ALTD platforms) Also paras 1.17–1.20 re: Downlinking Guidelines 2022 and Tariff Order 2017
⁸ Consultation Paper, Question 2, page 32.
⁹ Consultation Paper, under question 11, point G (para 2.73)
¹⁰ Consultation Paper, Question 1, page 31
¹¹ Consultation Paper, Question 2, page 32
¹² Consultation Paper, Question 3, page 43; along with question 8, page 52
¹³ Consultation Paper, Question 4, page 44; along with Question 5 (page 45), Question 6 (page 47), Question 7 (page 47)
¹⁴ Consultation Paper, Question 9, page 53 and 54, along with Question 10 (page 56)
¹⁵ Consultation Paper, Question 11, page 58
¹⁶ Consultation Paper, Question 12 and 13, page 61
¹⁷ Consultation Paper, Question 14, page 62

TRAI Consultation Paper on Regulatory Framework for Application-Based Linear Television Distribution (ALTD) Services (Including Free Ad-Supported Streaming Television (FAST) Services)