Understanding National Digital Communication Policy For Startups And Cloud Telephony Players

iSPIRT has been actively engaged in pursuing the favourable policy for the Cloud Telephony sector in Telecom Industry, an amalgamation of the various IT and Communications technologies.

National Digital Communication Policy has been announced recently and it is encouraging to see the announcements in the policy on some common issues to do with Startup ecosystem and digital communication aspects of the Cloud Telephony Players.

We are expecting the Department of Telecom (DOT) to further work on implementation and framing of rules and regulation in light of policy in near future. Despite many positive directional changes, there is a need to develop a regulatory framework for the Cloud Telephony players. Cloud Telephony players are adding value to communication and hence to the economy in several innovative ways. In addition, they also add a good revenue stream to licenses Telecom Service Providers (TSPs).

This PolicyHacks session is devoted to the critical analysis of the NDCP for this sub-sectoral player. Some of the entrepreneurs involved in the discussion are Gurumurthy Konduri of Ozonetel, Ujwal Makhija of PhoneOn, Gaurav Agrawal of Exotel and Gaurav Sawhney of Knowlarity.

A recording of this discussion is given below. Please feel free to click and watch. (About 20 seconds lost in the opening frame, apologises for the error)

The main point covered in the discussion is summed up below as are the some of our recommendations and good work is done (while the Policy was in the draft stage and during various consultation processes), which have been reflected in the policy under respective sections as under:

Page 7

1.1.(f)   – Encourage and facilitate sharing of active infrastructure by enhancing the scope of Infrastructure Providers (IP) and promoting and incentivising the deployment of common sharable, passive as well as active, infrastructure

1.1.(g).iv.  –  Allowing benefits of convergence in areas such as IP-PSTN switching.

Both of these are encouraging moves however it is to be seen how further rules and framework make easy for Small and Startup companies to use them without licensed TSPs creating a barrier for them.

Page 8

1.1.(j) – By encouraging innovative approaches to infrastructure creation and access including through resale and Virtual Network Operators (VNO)

This is a very encouraging announcement for the Cloud Telephony startups.

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2.1. (c ) iv. – Improving the Terms and Conditions for ‘Other Service Providers’, including definitions, compliance requirements and restrictions on inter-connectivity

2.1.(c ).viii. – Creating a regime for fixed number portability to facilitate one nation – one number including portability of toll-free number, Universal Access numbers and DID numbers

Again very encouraging but needs some boost up. Audiotex regime must go most speakers feel and all the players in Cloud telephony are treated as ASP. These provisions will help cloud telephony to deliver better value propositions in their offerings.

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2.2.(a) iv:  – Encourage use of Open APIs for emerging technologies

2.2. (b) – Promoting innovation in the creation of Communication services and network infrastructure by Developing a policy framework for ‘Over The Top’ (OTT) services.

2.2.(f) ii.  – Enabling a light touch regulation for the proliferation of cloud-based systems

2.2.(f).iii. – Facilitating Cloud Service Providers to establish captive fibre networks.

A welcome move to encourage Open APIs. However, licenses TSP should be given one standard that is governed by DOT to implement any APIs that let them monitor cloud telephony or ASPs on their network, instead of allowing them to create a regime of their own.

Generally, an OTT policy is recommended in reforming the sector. However, OTT framework should not be mixed with ASP or Cloud Telephony providers. It is better to keep a distinction between the two.

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2.4.(a).ii: – Promoting participation of Start-ups and SMEs in government procurement

2.4.(b).  – Reducing the entry barriers for start-ups by reducing the initial cost and compliance burden, especially for new and innovative segments and services.

Acceptance of these issues is very encouraging. The Government can be a very big user of the Cloud Telephony industry also. And we hope this will turn out to be a winning proposition for the Cloud Telephony industry in near future.

Conclusion

Whereas this policy announcement reflects a positive change, it is yet to be seen how DOT look at Cloud Telephony and provides it with a recognition as a sub-sector with easy and proper regulatory framework for same.

Note: The above article is co-authored by Gurumurthy Konduri of Ozonetel with Sudhir Singh of iSPIRT

Cloud Telephony Startups seek support from TRAI

This write-up should be read along with the previous blog – The Value Added Service Providers in Cloud Telephony. These blogs help us to accumulate the progressive development in discourse on policy for this segment of Industry. It is important for our common understanding and help Software product industry innovating in telecom sector in general and cloud telephony in specific terms.

The Startups providing Value Added Services also refereed to as Cloud Telephony submitted their response to Consultation Papers by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence. 

TRAI also received responses from other service providers (which includes licensed Telecom Operators and ISPs) and Industry Bodies and Individuals. iSPIRT response was also submitted on the due date and can be accessed here from TRAI website.

The responses have been analysed and as required the counter comments have  been filed with TRAI.  Given below is our Response submission.

Counter Comments to responses received on Consultation paper by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence. Dt. 08/08/2016


After reading the responses to consultation papers, it is evident enough, that there is a clear divide between the Startup or SME players and the Telcos or the industry bodies representing them.

As previously described by us, almost all companies presently providing the services in this (voice mail/Audiotex) space are startups or SME players who have built their own Software products. Unified license operators are already allowed to provide these service. So, there is no barrier for them to enter in to these services, except creating specialisation around these services and building the requisite Software that runs the service.

The licensed Telecom operators in their responses to consultation paper have blindly favoured a license regime in this space, as well as attempted to make the case of revenue loss and breach of license. This is clearly an attempt to hog the telecom sector landscape.

We believe the approach taken by the large players in the Industry is contrary to the direction, thought and objectives of present Government. It confronts the principles of building an innovative society and multiplying growth opportunities for the enterprising youth of our country.

Recognize them as value added Services

We already stated this in our response earlier submitted. However, it seems there is a need to reinforce the point.

The services provided in this space are highly specialised “Value Added Services”. They are by no means either the carriage services or network services. It is a layer on top of the existing mobile and basic telephony that delights the consumer by fulfilling their needs that basic/mobile telephony cannot.

Value Addition is done on the services hired from licenses telecom operators, which have already been subject to revenue share mechanism. Hence, the very claim that these services can be sold at a cheaper rate than the local calls is squarely an imagination. So, also the revenue loss story does not stand any ground.

Therefore, the need to recognize this aspect of “Value Added Service” providers, is primary to any policy framing under consideration on the subject.

Regulate doesn’t imply inevitability of license

There is a serious need to catch up with technological advancements. A large country like India can’t be left to mercy of few companies on this account. This calls for reform and further deregulation of the telecom sector to a degree that it is accommodates the changes from time to time.

In order to allay any doubts of the stakeholders in this sector and better value to the consumer, there may be need to regulate this sub-sector of Value Added Service provider.

Regulation does not always mean “a license”. This value added service sub-sector does not hurt the incumbent licensees in any way. Hence, a simplified regulated regime with lower administrative burden and lowers costs is desirable for suitability to this segment of the telecom sector.

Hence, a registration system with period monitoring and control rather than a license regime has been recommended by us.

Promote Innovation in Digital economy

Indian is entering in to a ‘Digital Economy’ era. Digital India is also not just about connectivity and switching networks. So, a ‘Digital India’ cannot be created by just handful of licensed Telecom players. The consumer in a digital economy is going to consume variety of data and application. Innovative Software products can power up the Digital India to make it a functional ‘Digital Economy’.

Innovation is going to be the lubricant of future digital economies

This segment of the Value Added Service has been born out of innovation of individual entrepreneurs and service provision works on Software products. So, also the commercial part of the service in integrated manner.

At this juncture, when India is wanting to unleash the innovative power by its StartupIndia policy, the license raj or barrier created by large Telcos can be counterproductive to digital economy or the Digital India dream.

Telecom sector and telecom policy at large has to imbibe this need to create friendly promotional environment for innovation to happen. It is not hidden from any one that innovation worldwide is being driven by individuals and small players.

All stakeholders in telecom sector including the licensed telecom operators should contribute to Innovation. Hence, the need to support these small Value Added Service providers and welcome the new ones to emerge.

iSPIRT Request

We seriously feel that growth cannot come from fixing ourselves to status quoist approach. There is a need to further add value to the telecom sector and hence a need to create scope for number of small players to contribute to the overall telecom sector.

There is a huge opportunity for Indian Software industry to innovate and contribute to telecom sector. We from iSPIRT, request that TRAI takes the above points and our earlier response submitted in to consideration and create an enabling environment for India to grow.

The Value Added Service Providers in Cloud Telephony

Industry discussion on response to Consultation Papers by TRAI on Voice Mail/Audiotex/Unified Messaging Services Licence

TRAI floated a consultation paper to review the license of Voice Mail/Audiotex/Unified Messaging Services. The consultation paper throws light along with an in-depth analysis of various issues involved.

Many call these companies as Cloud telephony companies. Cloud telephony is a wider terms. Plus its creates confusion on switching happening from cloud. This can be problematic for a dialog with TRAI or DOT. Hence, We have called them as Value Added Service Providers. This argument is justified in this discussion below.

For iSPIRT this sector is important as

  1. Most of these companies have a Software product at the core developed by them
  2. They are mostly startups and
  3. There is enough scope in  this sector for more innovation to happen.

iSPIRT conducted a discussion on important issues of this segment of the Industry. The discussion was to touch on important aspects of the consultation papers of TRAI. The discussion is organized in 4 parts as follows:

  1. License issues
    • License v/s no license, separate licenses Technology and license mapping
    • Entry Fees, Revenue Share, License Period
  2. Issues like conferencing, dial out, point-to-point conferencing
  3. Unified License – how to tackle this
  4. Focus on innovation, Startups, Ease of Business (compliance)

Following people from Industry joined the Discussion:

  1. Ambarish Gupta, Sandeep Upadhyay and Sriram from Knowlarity
  2. Gurumurthy Konduri from Ozonetel
  3. Shivakumar Ganesan – Exotel
  4. Anik Jain – Myoperator
  5. Ujwal Makhija  – Phonon

Those interested can watch the video embedded here. Also the text below the video describes the common points and agreements of the essence of the discussion.

License issues

There are several questions asked in consultation paper on, What kind of licensing is required for various services. (Q1 to Q8)

At iSPIRT we feel most of these providers fall under one category. And they all should get recognition under one category name. This will include all, those who provide Voice mail, Audiotex, Audio Conferencing service etc. They can focus on one set of service or the entire suit of services.

Nomenclature – Call them Value Added Service providers

Cloud Telephony means a telephony service provided from cloud hosted infrastructure. simple reason that the service offered from cloud. Present policy regime of India calls them content providers. Now this may be difficult to digest for remaining IT industry. This include  provider licensed under the Voice Mail/Audiotex/Unified Messaging Services License.

Application service provider (ASP) and Communication application service provider (CaaS) are other nomenclatuers ascribed.

These providers are not supposed to carry telecom traffic or provide switching of telephony. In essence these providers are “Value Added Service” (VAS) providers. These value added services can range from be voice mail box, an IVR, a virtual PABX, a virtual call center to analytics based services.  There can be lot of innovative ways to deliver services. The VAS operator charges for their value added part. The VAS operator does not have its own network but relies on network resources of the Telcos for the basic or mobile telephony.

Weather a license or a simple Registration process

Everyone in the panel agreed that licensing cumbersome and costly. There is no need for a license and that there should be a simplified registration process.

The registration should be under one category e.g. Value Added Service Providers. This can cover all Voicemail, Audiotex along with Audio conferencing and the Unified messaging.

The registration helps DOT to keep track of fair use of the policy, with complete neutrality and level playing field. DOT can keep watch the registered VAS providers through a simple compliance process.

License issues – Entry Fees, Revenue Share, License Period

There was common agreement in the discussion on fees and charges. Presently there is a bank guarantee of 3 lakhs for Voice Mail/Audiotex licenses. A policy to either keep it at same level or evolve to simplify further is welcome.

License/registration period of 10 or 20 years are good enough.

Issues like conferencing, dial out, point-to-point conferencing

The consultation paper deals at length these issues. For the industry they are of high importance as most confusions arise from them. Often the threats of inspection and service disruption from TERM cell arise from these provisions. There is always a doubt that the VAS operator may be involved in routing call traffic for business motives or running a switching service clandestinely.

In such a dubious doubtful environment this budding segment of Industry cannot grow. The VAS operators addes lot of value to both their suppliers and clients. The customer pays for the value they add not for the telephone calls. For suppliers (Telcos), the VAS operator is a bulk service customer

The common agreement was that this area needs a serious look from TRAI and DOT.

When industry is complying with all required prohibited clauses of the policy such as

  1. No VOPI integration
  2. No toll bypass
  3. No number masking

When the Call deail record (CDR) are all tapped in the Telco’s network;

AND

When there are further detail logs and records that are avaialable from VAS provider;

there does not arise a chance of

  1. Security  breach by VAS operators and
  2. Revenue loss to Telcos

The revenue of Telcos increase happen to increase even when they VAS providers buy from Telcos at a discounted rate. VAS operators increase the size of Pie.

In view of above, the common agreement in the discussion was that

  1. There should be clarity on conferencing, bridging call out provisions
  2. There is nothing like point to point conferencing
  3. The policy should allow VAS operators to use telecom resources from multiple operators. The limiting principle should be dial out to same operator from where incoming call comes.  Multiple operators are the need for reliability or redundancy.

OSP like provisions or OSP should be allowed for VAS providers?

There was an opinion on OSP being allowed to VAS operators. This will give them more flexibility to operate and grow their presence. The opinion attempts to justify the OSP based on analogy of large Captive call center operators allowed OSP with network spanning country wide with a central logic running.

iSPIRT’s opinion is that this may create conflict with other areas of policy under TRAI and also face sever resistance. It is advisable to take up this issue in a phased manner. May be first limiting OSP to one telecom circle at a time. Plus it advisable to approach it, after due consultative interactions with TRAI and DOT.

Unified License – how to tackle this

There are number of questions on Telcos operating under unified license to offer VAS. The questions also point to inclusion of “Voice Mail/Audiotex/Unified Messaging Services” in unified license.

The common opinion that emerges out from discussion is that the Value Added Services is a different ball game. The market should be free for all. Eventually there is a unique Software Product existing behind these services. The quality of service is highly dependent on this core product.

There does not seem to be any apposition to Unified license getting extended to the value added service suit.

Focus on innovation, Startups, Ease of Business (compliance)

This fourth part got truncated from the recording, perhaps for time limit getting crossed unnoticeably.

For benefit of the community. A very short discussion on how this small industry could further be boosted by perhaps giving more access to domestic market through promotional policy measures.

Certainly there is agreement that there is lot of scope to innovate and do more within this segment of the Industry.

The discussion ended by a Thank you note.