The Telecom Regulatory Authority of India has issued an “advisory” to all DTH Operators to enable, specifically, UPI payments and the Bharat QR code, saying that DTH operators “may” enable digital payments through UPI and onboard billers on the Bharat Bill Payments System, print the Bharat QR code on DTH bills, apart from sending pull requests to customers through their virtual payment address on a UPI enabled app. Apart from that the TRAI has also “advised” that DTH operators “may” offer a visible discount to customers on digital payments, and organise a campaign for promotion of digital payments. The TRAI has shared a template which DTH operators “may” submit to the TRAI about the digital payment enablement of their DTH operations.

A few things

It’s worth noting that this is a direction worded as an advisory, and appears to be in the “voluntary but mandatory” and “a request but an order” category. You can’t really choose not to comply with this apparent order. You even have to give data to the authority on the status of the deployment. The advisory doesn’t mention the specific section of the TRAI Act, from which the regulator draws its powers, for it to issue such a direction-like advisory: What part of the TRAI Act governs which payment mechanisms a DTH operator might deploy?

But the second issue is that digital payments are not necessarily UPI, so it’s not clear why the TRAI is . UPI is a payments protocol run by one private entity: the bank-owned National Payments Corporation of India. An alternate to UPI is wallet based payment, which are also run by other private parties.

So the question is: Why is a supposedly independent telecom regulator choosing between UPI and wallets, or choosing to benefit banks/NPCI/UPI app companies over wallet companies?

Of course, that is not to say that the deployment of digital payments is not a good thing, and DTH operators, and other service providers, ought to adopt digital payments, but it should be a matter of choice, and they should have to right to choose which digital payment mode they want to offer to customers: whether it is wallets, or UPI, or even IMPS. Why is the regulator picking winners here?

Why affinity does the TRAI have for UPI and why? Why are DTH providers being asked to allocate money towards promoting digital payments?

The TRAI advisory

Advisory to All DTH Operators for Enabling Online Payment System using BHIM UPI & Bharat QR code. Government of India is making efforts for promoting a less cash economy and Digital Payments in various utilities. To achieve the above mentioned objectives, the Government is working with multiple stakeholders for promotion of digital payments

2. DTH Sector is a vibrant sector and has a large consumer base. Enabling bill
payments in such sector, through digital means, would certainly provide convenience to
consumers as well as it would be cost effective proposition for the service providers.
3. In view of the above, the Authority is of the view that the DTH operators may
undertake the following activities to enable digital payments.
a) Enabling online payment system of Billers with BHIM! UPI and Bharat QR code.
b) Onboarding of Billers on Bharat Bill Payment System (BBMS)
c) Printing of Bharat QR code (preferably dyriamic) on DTH bills
d) Enabling at least two of the following options in all physical payment receipt
counters:
• Pull request through Mobile no. Nirtual Payment address (VPA) wherein a
request of bill amount is received on BHIM/ UPI enabled App of the
customer.
• Prominent display of printed static Bharat QR code on the billing counter to
enable customer to scan and pay.
• Dynamic Bharat QR code on a display facing the customer.
e) Offer a visible discount on digital payment vis-a-vis cash.
f) Organizing campaign for promotion of Digital Payments.
4. In this regard, a template has been annexed herewith, in which the DTH operators may provide information about digital payment enablement in their DTH Operations.