At the centre of submissions filed by Culver Max Entertainment and Jio Platforms to TRAI’s consultation paper on regulating Application-based Linear Television Distribution (ALTD) and Free Ad-Supported Streaming Television (FAST) services is a shared claim: FAST sits in the application layer and functions as an OTT service, not a telecom or broadcasting carriage service. In comments submitted to the Telecom Regulatory Authority of India (TRAI), both companies argued that FAST platforms may look like television channels, carrying scheduled programming and ads, but still run over the open internet on a consumer’s existing broadband or mobile connection.
TRAI’s consultation paper seeks views on whether such services should face a regulatory and authorization framework similar to cable TV, DTH, HITS, or IPTV operators. Both companies, however, argued that doing so would collapse the long-standing legal distinction between internet services and licensed broadcasting networks.
FAST is OTT, not broadcast carriage: Both submissions insist that format does not change character. Jio says OTT content remains OTT “irrespective of whether the content is scheduled or non-scheduled and irrespective of whether it carries and is supported with advertisement or not; such content delivery through internet remains OTT services.” It argues that FAST is simply a category of OTT because it is delivered over the public internet and is free at the point of consumption.
Sony makes the same broad point, saying ALTD and FAST operate “at the application layer” and are “structurally, technologically, and conceptually distinct” from the network infrastructure that supports telecom services.
Jio also says scheduled streams on platforms such as JioTV and YouTube still qualify as OTT, while Sony says FAST sits apart from linear broadcasting because it relies on user choice rather than one-to-many distribution.
TRAI is targeting the wrong framework: From there, both companies argue that TRAI is trying to apply a broadcasting model to services that live on the internet. Jio says OTT media services use open, shared internet infrastructure and do not rely on scarce resources such as spectrum or dedicated carriage networks. Sony says the same broad distinction applies: ALTD and FAST platforms are “users of telecommunication networks, and not providers of telecommunication services.”
Jio adds that the consumer pays the ISP separately, while the platform either charges nothing or charges a separate content fee. That structure, it says, makes FAST platforms fundamentally different from traditional broadcasting, where carriage and content charges are bundled by Distribution Platform Operators (DPOs). Both companies argue that no separate telecom-style authorization should be imposed on application providers.
The legal boundaries and jurisdiction: Sony goes further on jurisdiction. They argue that TRAI’s role in broadcasting…
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