The Telecom Regulatory Authority of India has extended the date for submission of comments on its proposal to regulate mobile Value Added Services in the country, to the 23rd of August 2011. Please submit your comments to the TRAI at firstname.lastname@example.org or email@example.com. Download the consultation paper here. They’re seeking answers to just 10 questions, so do write to them.
We’ve just completed our recommendations for submission (since the today was supposed to be the deadline). Click here to download our recommendations.
The executive summary is below, but we’ve explained our rationale for the recommendations, and specific responses to the 10 questions in the document. We’re open to feedback and suggestions for changes from you, our readers, so please feel free to write in. We’ll submit the final recommendations next week.
1. MediaNama.com, the premier website for news and analysis of the digital ecosystem in India, welcomes the TRAI’s interest in ensuring the creation of a healthy and flourishing Mobile Value Added Services ecosystem, since this industry is an integral part of the nascent Digital ecosystem in the country, with the potential to impact the livelihood of hundreds of millions of individuals.
2. Mobile Value Added Services companies are currently operating as vendors to telecom operators, and the provisioning of their services and their fate is entirely in the control of the UASL/GSM/CDMA Access Service Providers. The MVAS business is already regulated by the authority through these Access Service Providers, and as such, we do not feel there is a need for further regulation of Mobile Value Added Services companies. Licensing is out of the question, since the digital content and services ecosystem is at a nascent stage, and licensing would act as a deterrent to entry of startups and smaller companies, which are often the most innovative.
3. The lines between MVAS, the Internet, Broadband VAS, DTH VAS, and services on connected devices (from tablets to cars and refrigerators) will blur in a ubiquitous environment, and any initiatives from the authority must take this into account: please view these services as being delivered over Internet Protocol, and not by platform company or access service provider. Digital Ubiquity is the future, and companies are Digital Service Providers, not just MVAS companies or Internet companies.
In that context, we would request the authority to initiate steps to break existing cartels, ease setting up of new businesses and unshackle these Digital Service Providers. This can be done by focusing on three changes:
a. Separation of ownership of identity of the Digital Service Provider from provisioning by Access Service Provider by creating a Common Short Code Registry, governed by a Common Short Code Registrar. At present, Digital Service Providers do not own the short codes they operate.
b. Separate billing for services/content from access charges, to bring transparency and standardization in consumer billing, and independence for the Digital Service Provider from Access Service Provider. We would recommend the removal of the existing revenue share mechanism as a means to ensure ubiquitous pricing mechanisms across digital platforms.
c. Enforce provisioning of independent mechanism for verification of billing, in order to address MIS issues, and bring billing for content and services in line with Mobile and Online Banking guidelines from the Reserve Bank of India