DoT/TRAI regulations for enterprise UC are a challenge
“I have heard that there are restrictions to how conferencing can be configured in India. What are the rules and regulations regarding voice conferencing in India? I can’t seem to find any real information about it. Is my current conferencing solution TRAI compliant?” – Genuine concern from a compliance executive.
The Telecom regulatory authority of India (TRAI) is the regulator for all telecommunications, internet, broadband and other services. TRAI mandates specific regulations based on the telecom laws defined by the Government of India in consultation with the Department of Telecommunications (DoT).
The Government of India, through the Indian Telegraph Act 1885, New Telecom Policy 1999 and National Telecom Policy 2012, has defined multiple licenses for different services provided by the operators like internet, cable, telecom etc. As newer technology like internet telephony has arrived, they have tried to strike a balance between the consumer benefit and revenue protection for existing service providers who have heavily invested in the infrastructure.
For enterprises having a CUG (Closed User Group) through standard Unified Communications (UC) solutions, this translates to a set of TRAI regulations that restricts how their solutions can be architected.
Why the conferencing solution needs to be toll compliant
The TRAI regulation has a blanket statement that says, any call using PSTN resources that results in toll bypass for the service providers, is not compliant. Enterprises with a PBX could very easily violate the TRAI toll compliance regulations if they are not vigilant.
So, what does this mean for an enterprise? What scenarios does the enterprise guard against?
Is your conferencing solution allowing a user from the office deskphone speak to a user calling from a mobile on the conference bridge? Are you able to dial an internal extension to join a conference, while another party joins from the PSTN on the same bridge? If your answer to either of these questions is yes, then there is a high possibility you are bypassing toll.
If on the same conference bridge an enterprise CUG party and a PSTN party are present, then there is a toll violation happening, since a long-distance toll might be bypassed. So, for example, an enterprise user in the office at Bangalore calls into a conference bridge located in Delhi, and a mobile user in Delhi calls into the same bridge over a PSTN trunk, then a long-distance call is effectively happening with local PSTN toll given to the service provider.
Who is checking?
Two entities that are primarily keeping an eye — DoT and the telephony service providers (TSPs).
The complete network architecture needs to be provided to the telephony service providers before they can provide a PSTN line to an enterprise. Additionally, they ensure strict numbering plans and logical partitioning are put in place to stay toll compliant.
DoT conducts regular and periodic audits of enterprises with PBXs, and it is rare to see a DoT audit that does not find violations.
What are the consequences of non-compliance?
DoT audit findings have resulted in shutting of operations for many enterprises. Some enterprises with very fluid voice infrastructure due to constant acquisitions, have in fact chosen to get rid of a CUG to make sure they stay toll compliant.
In addition to the impact on operations, and the consequent financial loss, the enterprise would face fines and litigation. This is particularly applicable to call centers with OSP registrations.
Should I get rid of my UC solution?
That is an extreme step, and it is not required. Instead the enterprise needs to configure their UC solution to make sure that toll compliance violations don’t occur.
In the case of conferencing solutions, here are some options that an enterprise can pursue without bypassing toll
- Enterprise only conference bridge — Establish a conference bridge for the enterprise users only. These users can be located anywhere in the world and can access the bridge through the enterprise network. The only restriction is to ensure this enterprise conference bridge is logically separated from any type of Indian PSTN trunk. This means that any call involving PSTN trunks cannot land on the enterprise only conference bridge.
- External conference bridge with PSTN routing for enterprise user — Establish a conference bridge outside of the enterprise network (either by the same enterprise or a third-party service). All PSTN users can directly call that conference bridge over the PSTN trunks, and the enterprise routing needs to be configured in such way that any call to the conference bridge is routed over the PSTN trunk local to that user. This ensures that all calls to the external conference bridge are over PSTN and that toll bypass does not occur at any point.
- Internal and external conference bridges — Many enterprises choose to have both, an internal and an external conference bridge. The internal conference bridge is used when all the parties are internal to the enterprise, while the external bridge is used when even one party is coming over the PSTN. The key to achieving this is to configure the routing within the system appropriately.