TRAI’s ALTD and FAST consultation paper raises a major question for India’s media future: should apps that stream scheduled TV channels follow broadcasting-style rules? This ABC Live analysis explains the difference between ALTD and OTT, the limits of IT Rules, 2021, and the need for a balanced, innovation-friendly regulatory framework.
New Delhi (ABC Live): India’s television market no longer moves through cable and DTH alone. Instead, a new category now sits between traditional television and OTT platforms: Application-based Linear Television Distribution, or ALTD.
ALTD refers to linear TV channels delivered via apps over the internet. These apps may appear on smart TVs, mobile phones, web platforms, operating-system app stores, or pre-installed device applications. TRAI uses ALTD as a wider term that includes FAST services, because these services distribute scheduled TV-like channels through apps.
Therefore, the issue goes beyond technology. OTT gives users an on-demand choice. ALTD provides users with scheduled TV channels through its apps. As a result, ALTD looks like OTT in delivery, but it behaves like television distribution in function.
Consequently, India now faces a regulatory question:
Should an app that distributes linear TV channels carry broadcasting-style responsibility?
What Is ALTD?
ALTD refers to application-based distribution of linear television channels. In simple terms, it means TV through apps.
For example, a user may open a smart TV app and watch a scheduled news, movie, music, devotional, or entertainment channel. The user may not choose the exact programme—instead, the platform streams channels in a fixed schedule, like traditional television.
Key Features of ALTD
| Feature | Meaning |
|---|---|
| Delivery mode | Internet/app-based |
| Content style | Linear/scheduled channels |
| Device access | Smart TV, mobile, tablet, web |
| Revenue model | Mostly advertising-supported |
| Regulatory concern | Similar function to TV distribution |
How ALTD Differs From OTT
OTT generally offers on-demand content. Therefore, users choose what to watch and when to watch. ALTD, however, offers scheduled channels, so users watch what the platform streams at that time.
ALTD vs OTT
| Point | ALTD / FAST | OTT |
|---|---|---|
| Main format | Linear TV channels | On-demand films, shows, series |
| User control | Limited | High |
| Viewing style | Schedule-based | Choice-based |
| Example | FAST channel on smart TV app | Netflix-style content library |
| Revenue model | Mostly ads | Subscription, ads, or hybrid |
| Regulatory issue | TV distribution accountability | Digital content governance |
Interpretation
Thus, ALTD is not ordinary OTT. It uses internet delivery, yet it performs a television-distribution function. Therefore, TRAI rightly examines whether ALTD providers need a separate regulatory framework.
What are the IT Rules, 2021?
OTT platforms in India mainly follow the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. These rules regulate digital media content, online curated content, grievance redressal, and self-regulation. The rules create a three-level structure: publisher-level grievance handling, self-regulatory body oversight, and government-level supervision.
However, these rules do not create a broadcasting licence system. Moreover, they do not directly regulate channel carriage, EPG placement, tariff parity, interconnection terms, or distribution accountability.
IT Rules, 2021 vs Broadcasting Regulation
| Issue | IT Rules, 2021 | Broadcasting/DPO Regulation |
|---|---|---|
| Entry permission | No broadcasting licence model | Licence/authorisation/registration |
| Main focus | Content ethics and grievance redressal | Distribution, carriage, compliance, tariff, quality of service |
| OTT coverage | Yes | Generally no |
| ALTD coverage | Unclear and insufficient | Under consultation |
| EPG/channel placement | No specific control | Possible control |
| Pay-channel leakage | No clear answer | Can address it directly |
Interpretation
Therefore, the IT Rules, 2021 can regulate content conduct, but they cannot fully regulate app-based distribution of linear TV channels. Consequently, TRAI needs a separate ALTD framework.
India’s Regulated TV Ecosystem and ALTD Gap
TRAI records that India has 300+ broadcasters, 774 registered MSOs, 1 HITS operator, 4 pay DTH operators, 70+ IPTV providers and 81,706 LCOs.
Regulated Television Ecosystem
| Segment | Scale / Position |
|---|---|
| Broadcasters | 300+ |
| Registered MSOs | 774 |
| HITS operators | 1 |
| Pay DTH operators | 4 |
| IPTV providers | 70+ |
| LCOs | 81,706 |
| ALTD/FAST platforms | Outside a structured framework |
Interpretation
This table shows a sharp regulatory imbalance. Traditional platforms follow licences, registrations, content codes, tariff rules, and reporting requirements. However, ALTD platforms may provide similar channels through apps with fewer obligations. As a result, the market faces regulatory arbitrage.
Market Data: Why TRAI Cannot Ignore ALTD
TRAI relies on market data to show rapid growth in FAST and connected TV. India’s FAST revenue stood at USD 63.69 million in 2023 and may reach USD 104.10 million by 2027. Similarly, FAST users may grow from 116.4 million in 2023 to 148.6 million by 2027.
FAST Growth in India
| Indicator | 2023 | 2027 Projection |
|---|---|---|
| FAST revenue | USD 63.69 million | USD 104.10 million |
| FAST users | 116.4 million | 148.6 million |
Interpretation
This data shows that FAST has moved beyond experimentation. Instead, it now forms a growing parallel television economy. Therefore, regulatory delay may distort competition, weaken consumer protection, and create uncertainty for investors.
Connected TV Shift
TRAI records that India’s connected TV audience grew from 69.7 million in 2024 to 129.2 million in 2025. It also records that small towns and villages accounted for 75.8 million connected TV viewers.
Connected TV Growth
| Indicator | Value |
|---|---|
| CTV audience in 2025 | 129.2 million |
| One-year growth | 85% |
| Small towns/villages CTV audience | 75.8 million |
Interpretation
This growth changes the regulatory stakes. Earlier, internet TV looked like an urban premium service. Now, connected TV has entered smaller towns and villages. Therefore, ALTD regulation will affect access to mass media, regional content markets, advertising revenue, and public information flows.
Structural Complexity of ALTD
TRAI identifies several entities in the ALTD ecosystem, including TV manufacturers, operating system providers, application providers, content aggregators, broadcasters, and technology partners.
ALTD Ecosystem
| Stakeholder | Role |
|---|---|
| TV manufacturers | Provide devices and sometimes pre-installed apps |
| OS providers | Control app environment and app stores |
| Application providers | Aggregate and stream linear channels |
| Content aggregators | Onboard and package content |
| Broadcasters/content owners | Supply channels or content |
| Internet networks | Deliver streams to users |
Interpretation
Unlike DTH or cable, ALTD does not always involve one clearly accountable entity. Instead, the ecosystem spreads control across hardware, software, apps, content, and foreign affiliates. Consequently, TRAI must identify the application provider as the primary responsible entity, while also creating obligations for foreign-facing services.
Critical Regulatory Questions
TRAI’s consultation raises several core issues: definition of ALTD, responsible stakeholder, authorisation terms, pay channels on free platforms, consumer protection, audience measurement, and future regulatory treatment.
Key Questions and Their Importance
| Question | Why It Matters |
|---|---|
| Should ALTD get a legal definition? | It prevents ambiguity |
| Should app providers obtain authorisation? | It fixes responsibility |
| Should foreign platforms comply in India? | It closes enforcement gaps |
| Can pay channels appear free on ALTD? | It protects tariff discipline |
| Should EPG/home-screen placement follow rules? | It prevents platform gatekeeping |
| Should audience data follow standards? | It protects advertisers and consumers |
Interpretation
These questions show that ALTD regulation cannot remain limited to content complaints. Instead, it must cover distribution power, market fairness, consumer choice, data transparency, and platform accountability.
Critical Findings
TRAI Correctly Identifies Regulatory Arbitrage
TRAI correctly recognises that ALTD platforms may perform functions similar to those of DTH, MSO, HITS, or IPTV services. However, they often operate without equivalent obligations. Therefore, regulation must follow function, not merely technology.
However, Old TV Rules Cannot Be Copied Blindly.
At the same time, TRAI must avoid a copy-paste model. ALTD differs from cable and DTH because it uses apps, connected devices, algorithmic discovery, advertising technology, and data analytics. Therefore, the framework must remain proportionate and innovation-friendly.
IT Rules, 2021, are Relevant but Insufficient
IT Rules, 2021, help regulate digital content ethics and grievance redressal. However, they do not solve distribution issues. Therefore, India needs a separate ALTD framework for linear channel distribution through apps.
Consumer Interest Needs Stronger Protection
TRAI’s paper gives strong attention to industry parity. However, consumers may benefit from free ad-supported access. Therefore, regulation should protect users without reducing access to free content.
Foreign Entity Control Needs Direct Treatment
Some ALTD models involve overseas entities, third-party aggregators, and Indian-facing device platforms. Therefore, India must require a local compliance presence, a grievance officer, and an accountable entity for services offered in India.
Recommended Regulatory Approach
Suggested ALTD Framework
| Area Suggested | d Treatment |
|---|---|
| Pure OTT on-demand content | Continue under IT Rules, 2021 |
| Linear TV channels through apps | Treat as ALTD |
| FAST channels | Include within ALTD |
| Web-link aggregators | Use light-touch registration if curated |
| Foreign ALTD providers | Require India-facing compliance entity |
| Pay channels on free platforms | Require broadcaster permission and tariff compliance |
| EPG/home-screen placement | Mandate transparency and non-discrimination |
| Consumer complaints | Combine IT Rules-style grievance with broadcasting duties |
| Audience measurement | Require transparent and auditable standards |
| Small Indian platforms | Provide lighter compliance thresholds |
Interpretation
This model balances innovation and accountability. It prevents regulatory escape while avoiding crushing digital media innovation. Moreover, it protects consumers, traditional operators, broadcasters, advertisers, and emerging Indian platforms.
ABC Live Editorial Conclusion
TRAI’s ALTD consultation paper marks a turning point in India’s media regulation. The real issue is not whether ALTD uses the internet. It does. Instead, the real issue is whether an app that distributes scheduled TV channels should avoid accountability for broadcasting only because it does not use cable, satellite, or DTH infrastructure.
Therefore, India should follow a simple principle:
If a service behaves like television distribution, it must carry television-distribution responsibility. However, if it innovates like digital media, regulation must remain light enough to preserve innovation.
In conclusion, ALTD should not fall under ordinary OTT treatment. At the same time, it should not face a rigid legacy broadcasting regime. India needs a technology-neutral, function-based, consumer-first and proportionate ALTD framework.
Also, Read ABC Live TRAI Report
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