Faced with intense lobbying from telecom operators over the past few years, against opening up Internet Telephony (VoIP) to unlicensed players, the Telecom Authority of India has come out with recommendations only for Internet Telephony from licensed players.

In the recommendations, which the TRAI says are “limited to provisioning of Internet Telephony by access licensees”, it had addressed issues such as Internet Telephony across access service providers (whether Internet based telephony can be independent of the network”, security issues, numbering, and VoIP calls made while international roaming. Thus, there is still no clarity on interconnection between app based service providers to telecom operators, and it appears that that is still not allowed. We’ve awaiting a response from the TRAI, and will update if and when we hear from them.

In the meantime, app based VoIP providers have already suffered. The consultation paper was issued on the 22nd June 2016, and the regulatory uncertainty that has persisted over the last 15 months has cost at least one Internet Telephony service provider dearly: Nanu shut its operations earlier this year: it’s CEO Martin Nygate had told MediaNama then that its investors had pulled had declined to invest further in the company because of a lack of clarity on the recommendations: “Not only is it not out, but no one knows when it will come out or if it will ever come out”.

The TRAI must speed up its decision making, or not launch consultations without a reasonable time-frame in mind.

Downloads: Consultation Paper / Recommendations

Lowdown on TRAI’s VoIP recommendations

1. Internet Telephony services are independent of underlying access network: Some telecom operators had argued that Internet telephony can only be provided on their network to their subscribers. The TRAI held that this is not the case since Internet telephony is about the transfer of voice signal through the public Internet, and that “Public internet is a very general term and narrow interpretation taken by some of the TSP does not represent the correct position.”

“So, the Authority is of the view that as per the present licensing framework, Internet Telephony service can be provided independent of the Internet access Service. In other words, the Internet Telephony service is un-tethered from the underlying access network.”

Thus:

  • A telecom operator/ISP can provide Internet telephony services to its subscriber, who may be connecting to the Internet via another ISP/telecom operator, thus, un-tethered from the underlying access network. So, for example, Jio calling via VoIP can work independent of the telecom operator. The TRAI has said that the Department of Telecom (DoT) should issue a recommendation to this end.
  • The Virtual Network Operators, which license bandwidth/access services from telecom operators/ISPs and operate their own consumer services in licensed areas, should be allowed to provide un-tethered Internet
    Telephony in the designated service area.

The TRAI is also of the view that any ISP can provide unrestricted Internet Telephony either by obtaining a universal license with authorization to access services or can become VNO of any existing Access provider.

2. Interconnection issues: “The Authority observed that present recommendations are limited to provisioning of Internet Telephony by access licensees and they are handing over Internet Telephony call to other service providers like any other voice call and therefore there is no need to prescribe separate Interconnection framework at this stage and the extant POI framework and Interconnection Usage Charges may continue for provision of Internet Telephony services also. Moreover […] DOT has already stated that Internet Telephony service is akin to mobile service. However, if any change is required in the Interconnection regime , the Authority will issue separate amendment/clarification in this regard.”

3. Termination charges for International telephony calls: Internet Telephony calls by people who are on roaming should be handed over to the International gateway of licensed International Long Distance Operators, and pay International termination charges to the telecom operators / ISPs. If that doesn’t happen, then “International out-roaming to Internet Telephony subscribers of the access provider should not be allowed.”

Note that this will make international VoIP calls expensive in India, and essentially makes services like Skype-Out and VoIP based calling cards more expensive.

The TRAI has also said that “It is possible to ascertain from the public IP address of origination of Internet Telephony calls that whether the subscriber is located in India or abroad. It is also possible in GPS enabled handsets to ascertain the location with accuracy.” Wherever this is not possible, the calls will not be allowed.

Questions from the consultation paper that don’t appear to have been addressed:

Q5: What should be the termination charge when call is terminating into Internet telephony network?
Q6: What should be the termination charge for the calls originated from Internet Telephony Network and terminated into the wire – line and wireless Network?

4. For security, Public IP address mandatory as part of Call Data Records:  A key issue for the country has been interception of Internet telephony calls: these are difficult to trace and this issue was particularly problematic when the 26/11 attacks happened in Mumbai.

The TRAI has said that licensees should comply with all “interception and monitoring related requirements as specified in the”  UL(access services) license or VNO license, as applicable, and :

As far as the location of nomadic Internet Telephony subscribers is concerned, it is possible to capture the location details in case GPS service is enabled in GPS enabled Smartphone.

It has noted that in case of Internet Telephony using PC, only the IP address can be captured, “which may not provide the desired granularity for locating a mobile subscriber even after using the IPDR of the Internet access service provider”.

So, the Authority is of the view the Public IP address used for originating/terminating Internet Telephony calls should be made a mandatory part of CDR in case of Internet Telephony. The location details in form of latitude and longitude should also be provided wherever it is feasible.

In addition, Calling Line Identification Restriction facility should not be provided for Internet Telephony Subscribers.

5. On the Revenue Loss argument: As always telecom operators made the argument about revenue loss from customers switching to VoIP. TRAI said that “the Internet use is growing at an unprecedented high rate and existing providers will generate revenue from data services which will be required by a subscriber to make even an Internet Telephony call.”

It said that voice has already become an application over data services, and that this symbiotic relationship will help broadband proliferation. The “increasing revenue realizations from data services due to increasing Internet traffic will not only compensate for the loss of conventional voice traffic but will also increase the revenue potential of the last mile access networks.”

“The separation of network and service layers of telecom service offerings is the natural progression of the technological changes in this domain.”

“It is now possible to separate provision of service contents, configuration and modification of service attributes regardless of the network catering to such service.”

6. Numbering: Numbering is an important means of identification of the caller, especially from a security perspective. The TRAI has said that a mobile numbering series should be used for providing Internet Telephony by a service provider. Importantly, Telecom Operators “should be allowed to allocate same number to the subscriber both for Cellular Mobile service and Internet Telephony service.”

  • The SDCA linked numbering series may also be used for providing Internet Telephony by a service provider.
  • However, in this case, mobility should be limited to consumer premises the access service licensee should use private ENUM in its network for Telephone number mapping from E.164 to SIP/H.323 addresses and vice-versa.
  • In case of provision of Internet Telephony by VNO with access service authorisation, the numbering resource allocation should be done by the parent NSO.

7. Emergency calls and services: The TRAI has said the imposition of restrictions and mandatory obligations may “kill the initiative to provide Internet Telephony before a service can commercially pick up. In order to strike a balance, the Authority is of the view that Internet Telephony service providers may be encouraged to facilitate access to emergency number calls; however, they may not be mandated to provide such services at present”… “The subscribers may be informed about the limitations of providing access to emergency services to Internet Telephony subscribers in unambiguous terms.”

8. Quality of service for VoIP: is being left to market forces at present. “However, the service providers should ensure QoS as per the extant regulations in the managed part of the network which is not on the Public Internet. The Authority shall review the decision regarding mandating QoS to Internet Telephony service providers at appropriate time.”