New Delhi: The Telecom Regulatory Authority of India (TRAI) Tuesday announced a sweeping overhaul of the rules governing audits of cable TV and DTH operators, introducing strict two-strike blacklisting for auditors, giving broadcasters the right to attend distributor audits, and setting hard deadlines for post-audit disputes.
The new Digital Addressable Systems (DAS) Audit Manual 2026, which comes into force from 1 April, replaces the 2019 version of the manual and is the most significant rewrite of India’s pay TV audit framework in seven years.
It applies to all Distribution Platform Operators (DPOs) — including multi-system operators (MSOs) such as Den Networks and Hathway, DTH companies like Tata Play and Airtel DTH, and IPTV and HITS operators.
At the heart of the new rules is a problem that has plagued India’s Rs 70,000-crore pay TV industry for years—the persistent gap between the number of subscribers that cable and DTH operators declare to broadcasters, and the number they actually have.
Since carriage fees — the money channels like Star, Sony and Zee receive for their content — are calculated on declared subscriber numbers, any under-declaration directly hits broadcaster revenues. The audit system exists to catch this.
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Two errors, and you’re out
The most striking provision in the new manual concerns the auditors themselves— independent agencies empanelled by the TRAI to verify the subscriber data and technical systems of distribution companies. Under the new rules, an auditor who is found to have conducted two erroneous audits will be removed from TRAI’s empanelled list and blacklisted for two years.
The consequences do not stop there. The TRAI can forfeit the auditor’s performance bank guarantee—a financial deposit put up at the time of empanelment—report the firm to professional bodies such as the Institute of Chartered Accountants of India (ICAI) or ICWAI, and, notably, issue a public press release naming the erring auditor.
“The auditor and their staff must carry out tasks with the highest degree of professional integrity and technical competence. They must be free from all pressures and inducements, particularly financial, which might influence their judgment,” the manual states.
Auditors are also barred from auditing the same operator for more than three consecutive years and cannot take up an audit assignment where they are also the statutory, internal, or concurrent auditor of the same entity.
Broadcasters on the table
In a significant shift in the balance of power between broadcasters and distributors, the new manual — incorporating the Seventh Amendment Regulations notified on 5 February 2026 — gives broadcasters the right to depute one representative to physically attend the audit of a distributor’s systems.
This is a new right. Previously, the entity being audited had complete control over what was shown to the auditor during the process. Broadcasters have long complained that this arrangement allowed distributors to present only a curated view of their subscriber data.
Under the new rules, a broadcaster’s representative can attend to share inputs for verification but cannot direct or interfere with the audit. In audits initiated by broadcasters, no more than two representatives can be sent. The distributor is required to permit such a representative entry.
45-day window
The manual also sets a firm 45-day window—also introduced through the February amendment—within which broadcasters must raise any objections to an audit report after receiving it. After 45 days, the report is treated final.
This provision is designed to bring an end to the open-ended post-audit disputes that have routinely landed before the Telecom Disputes Settlement and Appellate Tribunal (TDSAT) and in courts, sometimes years after the audit in question was conducted.
Infra sharing gets audit rules
One of the most significant structural additions to the 2026 manual is the formal incorporation of audit rules for infrastructure sharing between operators.
The Ministry of Information and Broadcasting (MIB) permitted this practice for MSOs (Multi-System Operators) in December 2021, for HITS (Headend-In-The-Sky) operators in November 2020, and for DTH companies in September 2022, but which had no corresponding audit framework until now.
Under the new rules, operators sharing backend systems such as Conditional Access Systems (CAS) or Subscriber Management Systems (SMS) must ensure these systems generate entity-wise, individually segregated logs for each distributor using the shared infrastructure.
Auditors must separately assess what belongs to the infrastructure provider and what belongs to the seeker. A single CAS instance cannot be addressed by multiple SMS systems simultaneously — a provision TRAI says is aimed at preventing reconciliation failures that could obscure real subscriber numbers.
Practical fixes
The manual also addresses several compliance issues that had made the 2019 rules difficult to implement in practice.
CAS vendor compliance certificates, previously valid for only 30 days, have been extended to 90 days. TRAI’s own footnote in the document explains the reason—audits were regularly getting delayed after certificates were issued, and by the time the audit report was submitted, the certificates had expired.”
Audit completion timelines have been relaxed as well. A single-headend audit must now be completed within four weeks; multi-headend audits get eight weeks. The TRAI acknowledged in the document that existing timelines were “very stringent and difficult to meet”.
All audit data must be preserved for at least one year after the audit, on any medium including cloud storage. In cases where a legal dispute is ongoing, the data must be retained until the dispute is resolved.
The TRAI has also clarified a long-disputed procedural point: auditors cannot directly access or run commands on a distributor’s live CAS or SMS systems. Only the DPO’s own staff can operate the systems, with the auditor observing.
However, if the auditor doubts the output, the DPO must run any specific query the auditor requests, in the auditor’s presence, allowing verification of backend data against frontend reports.
(Edited by Ajeet Tiwari)
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