The Telecom Regulatory Authority of India (TRAI) has released a draft audit manual for digital rights management (DRM)-based digital addressable systems, inviting stakeholders to submit comments by October 30, 2026. The proposed manual sets out how audits should be conducted, what records must be maintained and how responsibilities should be divided among distributors, broadcasters and auditors, particularly for IPTV-based television distribution.
What TRAI’s Draft Audit Manual Covers
TRAI published the draft Telecommunication (Broadcasting and Cable) Services DRM-based Digital Addressable Systems Audit Manual, 2026, on October 9. The consultation is part of the regulator’s ongoing work on auditing digital addressable systems used to distribute television channels.
Under the Telecommunication (Broadcasting and Cable) Services Interconnection Regulations, 2017, distributors of television channels are subject to annual audits of their digital addressable systems, including conditional access systems (CAS), subscriber management systems (SMS), DRM and related systems. Schedule X of the regulations sets out requirements for DRM-based systems, primarily those used for IPTV distribution.
The draft manual seeks to provide a more structured process for carrying out these audits. It covers the scope of work, documentary requirements, pre-signal and compliance audits, annual subscription audits and timelines for completing the work. It also proposes standard formats for vendor declarations, audit forms and audit reports.
Who Could Be Affected?
The proposed procedures are relevant to distribution platform operators (DPOs), broadcasters and auditors involved in DRM-based digital addressable systems. IPTV service providers and other stakeholders operating within the applicable regulatory framework may also need to examine the draft to understand how the proposed procedures relate to their operations.
For distributors, audit requirements can involve maintaining records, documenting system configurations and ensuring that subscriber-related information can be checked through the prescribed process. Broadcasters and auditors also have roles in the audit process, making the allocation of responsibilities and the use of standard documentation important areas for stakeholder feedback.
The practical impact will depend on the final manual and how its provisions apply to individual systems. The draft should not be interpreted as evidence that TRAI has already imposed a new, immediately enforceable set of audit procedures.
Why TRAI Is Seeking Stakeholder Comments
A consultation allows affected organisations to identify operational difficulties, suggest changes and provide evidence before a draft is finalised. In this case, stakeholders can comment on whether the proposed audit procedures, timelines, documentary requirements and reporting formats are workable across different DRM-based systems.
Industry participants may also assess whether responsibilities are clearly defined, whether the required records are available in practice and whether the audit process needs additional clarification. Specific, evidence-backed submissions can help TRAI identify areas where the draft may need revision.
The consultation is therefore a procedural step towards a more clearly defined audit framework. It does not, by itself, establish that every proposal in the draft will be adopted in its current form.
How to Submit Comments Before October 30
TRAI has invited written comments and suggestions supported by detailed reasons, justification and relevant data or evidence. The deadline is October 30, 2026.
Stakeholders can access the draft and submission details through TRAI’s official consultation page:
TRAI draft DRM-based Digital Addressable Systems Audit Manual — official page
TRAI has asked stakeholders to preferably send submissions electronically to advbcs-2@trai.gov.in and jtadvbcs-3@trai.gov.in. The regulator has also provided an online submission facility on its website, which requires users to log in to their TRAI account.
What Changes Immediately?
The release of the draft does not mean that the proposed manual has been finalised or that all of its procedures have immediately become mandatory. Existing regulatory requirements, including the applicable provisions of the 2017 Interconnection Regulations, remain the relevant framework while TRAI considers stakeholder feedback and decides on the next steps.
The next milestone is the close of the consultation on October 30. TRAI’s subsequent action will determine whether the draft is revised and how the final audit manual is issued. Until then, broadcasters, distributors and auditors can review the proposals and raise concerns about implementation, documentation and compliance.
For the broadcasting and cable industry, the immediate task is to examine the draft rather than assume that the final audit process has already changed.
