MUMBAI: While one of the prime targets of digitisation, the cable industry, was bringing transparency, the irregularities in the conditional access system (CAS) and subscriber management systems (SMS) have been major concerns for broadcasters. Bringing a ray of hope to many broadcasters, the Telecom Regulatory Authority of India (TRAI) released a consultation paper seeking comments on the issue. In their submissions, all broadcasters have strongly advised a need to define a framework for CAS/SMS systems and an industry body to be entrusted with the responsibility. 

Star India said that there is an urgent need to define a framework for CAS/SMS systems to benchmark the minimum requirements of the system before these can be deployed as presently there are many CAS and SMS systems deployed that do not have required features and capabilities for securing content and reporting accurate subscriber numbers. It added that robust framework is required in order to ensure that there is no possibility of manipulation of records and piracy/illegal retransmission of signals of channels by deployment of sub-standard CAS and SMS systems as the same leads to loss of revenue to the operator, broadcaster as well as to the government in form of taxes.

It also recommended that the technical framework must be strengthened by forming an autonomous body that will be responsible for defining the framework, accreditation of the vendors, ensuring timely upgradation of Schedule III technical specification and operational requirements and continued compliance by the CAS and SMS vendors with the requirements of Schedule III. The broadcaster added that the autonomous body may be set up by representatives of broadcasters or DPOs or CAS and SMS vendors only. This body shall be entrusted with the task of accreditation, upgradation of specifications with the involvement of technical experts, and through a consultative process with relevant stakeholders defining the framework. 

“However, till such time the autonomous body is set up, it is imperative that Schedule III of the interconnect regulations be amended at the earliest to reflect the proposed changes and to enable strict compliance of the requirements of the amended Schedule III by DPOs and CAS and SMS vendors in order to eliminate under-declaration, manipulation of subscriber numbers and illegal retransmission of TV signals and to enable the integrity of CAS and SMS systems. In the interim until the finalisation and setting up of the autonomous body, the CAS and SMS vendors shall be held responsible for compliance of Schedule III, through the DPO and the SLA between them, it added further.” 

Schedule III of the interconnection regulation specifies the benchmark features or technical criteria that the systems are required to comply with. In addition, there are provisions in Schedule III that entail CAS and SMS systems to conform to certain technical features to check the piracy.

Zeel Entertainment Enterprises Ltd (Zeel) said there is a need to define the minimum basic functionality (MBF) for every CAS/SMS system to be approved in the country. Irrespective of the technology deployed, the few basic criteria should be met. 

However, Zeel has suggested different entities rather than one autonomous body. “There are different roles which need to be performed by a different set of entities so that checks and balances are maintained and there is a concept of maker, checker, reviewer, auditor and adjudicator. The role of setting standards for CAS, SMS, MUX and DHE should ideally reside with a multidisciplinary body which has representation from relevant ministries of the government, TRAI, CDAC, STQC, broadcasters, major distribution platforms, major CAS, SMS, MUX, STB, DHE vendors, chip manufacturers, device manufacturers and noted academicians of international repute and TRAI empanelled auditors.

“Such an agency could work under the direct supervision of TRAI as they are well versed with the intricate issues of the industry and can bring realistic elements in a timebound manner. The body/agency drafting standards should not overlap with either the body/agency providing the certification and/or the body/agency in the role of audit of these systems at a later stage. All these three units should be watertight and completely mutually exclusive,” it added. 

According to Zeel, there should be a designated agency to carry out the testing and certification to ensure compliance with such a framework. It mentioned that TEC is the agency which is appropriately placed to carry such testing as they have been doing the same for Telco equipment and have processes and procedures in place for same. In addition to that, TEC has no direct involvement with the routine activities of the broadcasting sector, it will be able to act as an independent accreditor. 

Times Network also feels that changes are needed. “We feel that there is a need to define a standardised technical framework for CAS/ SMS systems to benchmark the minimum requirements of the system before these can be deployed by any DPO in India. The deployment of CAS/ SMS systems is suggested to be based on advanced embedded system backed by mandatory tests and necessary. CAS must comply with CSA-2 or CSA-3 standards of scrambling algorithm and embedded in SoC (“Security on Chip”) in STB,” it said.

It has also highlighted that the standards should be made keeping in mind that these are at par with global standards and are also useful from middleware perspective. It added that there may be a specific SOC for CAS TO minimise the chances of hacking. It should be endeavoured that no sub-standard systems can be deployed.

“We feel that an independent, autonomous, neutral body should be set up for defining the framework for CAS and SMS in India. The autonomous body may be set up by representatives of broadcasters, DPOs, CAS and SMS vendors, technology vendors, manufacturer or importers of devices, representatives of R&D Centres, members of regulatory bodies etc. who can be assisted by trained investigators, legal and law enforcement members, cryptography analysts and system/network security auditors,” the broadcaster added. 

Echoing the tone of Zeel, Times added that the autonomous body should take into consideration global best practices and standards while proposing and suggesting the framework or technical standards for India. 

Sony Pictures Networks India (SPN) is also of the opinion that there is an urgent need to define a framework for CAS and SMS/Systems to benchmark the requirements of the systems due to the reasons as stated in the foregoing clauses. Such new frameworks should be effective for all the existing systems as well. 

“We firmly believe that this would also help protection of content, removal of rampant piracy and under-declaration of subscriber base and enhancement of consumer choices and experience thereby benefiting all the stakeholders. Hence the urgency to create a framework that would look at resolving the issues as raised herein. Further, the CAS and SMS vendors supplying their systems to the DPOs within India should also be mandated to follow the Schedule III requirements read with the TRAI regulations strictly and they should be made accountable for the same,” it added. 

SPN has also proposed an independent industry body comprising mainly the technical members from all the stakeholders including government, broadcasters, DPO and the OEMs to define a framework for the concerned issue in the country. The task of this body should be to primarily define and set the framework for CAS and SMS/Systems, which should be a benchmark for future deployments. 

“A standardised framework is required for CAS/SMS systems to benchmark the minimum requirements of the systems before it can be deployed by any DPO in India. Unsecured CAS/SMS system may lead to theft of broadcaster’s content and cause loss to the public exchequer. Substandard CAS/SMS system also impacts the performance of STBs thereby leading to unnecessary harassment of end-users,” TV18 stated. 

Like its competitors, the broadcaster reiterated that industry body comprising of stakeholders from every level of the value chain should be entrusted with the task of defining the framework for CAS and SMS in India and that an industry-led body is best-suited solution that ought to be considered for the same. 

“The industry body, thus, incorporated should take into consideration the framework adopted worldwide such as Movie Labs, IBCAP, DVB, etc. while defining the framework for India. However, it is necessary that DPOs, as well as CAS and SMS vendors, are made amenable to the Industry Body. In this regard, requirements such as, mandating CAS and SMS vendors to register as other service providers should be introduced,” it added.