• Download the Manufacturers’ Association for Information Technology’s (MAIT) submission here. 
• Download LG Electronics India Limited’s (LG) submission here. 
• Download Tata Communications Pvt Ltd’s submission here. 
• Download the consultation paper here. 

LG and the industry body MAIT have urged the Telecom Regulatory Authority of India (TRAI) to exclude TV manufacturers and operating system providers from the scope of any future regulatory framework for Application-based Linear Television Distribution (ALTD) and Free Ad-Supported Streaming Television (FAST) services. 

In submissions to TRAI’s consultation paper, both argued that smart-TV makers merely provide hardware and software infrastructure, while application providers control content distribution, channel curation and monetisation. LG said the scope of ALTD services should be limited to entities that “actively curate, control, and distribute linear television content”. MAIT, meanwhile, argued that TV manufacturers are “per se out of the ambit” of the consultation. 

Tata Communications Limited (TCL) similarly distinguished between OEMs and application providers, arguing that responsibility for authorisation should rest with the entity that controls channel aggregation and consumer-facing services rather than with upstream technology providers. 

OEMs should not be treated as broadcasters: LG’s submission repeatedly argues that editorial control, not device ownership, should determine regulation. The company proposed defining ALTD services as application-based services operated by entities that hold distribution rights, curate content, and exercise editorial control. It argued that the “scope of ALTD Services must explicitly exclude Television Manufacturers and OEMs” because device makers do not aggregate channels, negotiate content rights or determine programming decisions.

The company further distinguished between application providers and hardware manufacturers, arguing that television makers merely provide hardware, operating systems and user interfaces. LG described TV manufacturers as intermediaries and “mere conduits”, comparing them to internet service providers (ISPs) and smartphone manufacturers that provide access mechanisms rather than content services. Regulating device manufacturers under an ALTD framework would amount to “regulatory overreach”, it argued.

MAIT advances a similar position: It said TV manufacturers and operating system providers “do not necessarily provide ALTD services” and therefore fall outside the scope of the consultation. The industry body warned that imposing certification or compliance obligations on television manufacturers would create an additional regulatory burden, disrupt product launch cycles and undermine ease-of-doing-business objectives. The body pointed out that TV manufacturers already “operate in a complex, multi-layered regulatory framework”.

The argument directly challenges proposals made by Zee Entertainment Enterprises Limited (ZEEL), which argued that television manufacturers and operating system providers should ensure ALTD applications available on their platforms are duly authorised and comply with regulatory requirements.

Application providers emerge as the focal point:  LG said the authorisation burden should fall on the entity that “actively manages, controls, and legally distributes the content”, namely the application provider. The company argued that OEMs act only as “neutral technology enablers” and cannot be classified as distributors. MAIT similarly acknowledged that application providers are the primary consumer-facing entity and the point through which advertising and content distribution are delivered. TCL also argued that application providers should be the primary authorised entity because they control channel aggregation, service presentation, monetisation and consumer interfaces.

Notably, this position mirrors arguments made by ZEEL despite wider disagreement over regulation. ZEEL also argued that application providers should be the principal authorisation holder because they aggregate channels, manage programme guides and directly interface with consumers.

Industry pushes back against television-era regulation: MAIT described the approach outlined in TRAI’s consultation as “highly regressive”, arguing that ALTD services operate over the internet rather than scarce broadcast infrastructure. It said applying DTH, HITS or IPTV-style rules would stifle innovation and subject a fundamentally different technology to an outdated regulatory framework.

LG similarly argued that FAST services differ fundamentally from cable and DTH platforms because they are free-to-consumer, do not rely on spectrum or dedicated distribution infrastructure and remain at a nascent stage of development. The company called for a “light-touch” framework with nominal fees, minimal entry barriers and explicit exemptions for OEMs. TCL adopted a somewhat more measured position, advocating a framework that is “technology-agnostic, proportionate, and outcome-focused” while avoiding the automatic extension of legacy cable and DPO obligations.

These arguments echo positions advanced by JioStar and Culver Max Entertainment (Sony), both of which argue that FAST services operate at the application layer of the internet and should not be subject to traditional broadcasting or telecom-style licensing frameworks.

Pushback against infrastructure-sharing mandate: LG and MAIT also opposed proposals to import traditional broadcasting obligations into the ALTD ecosystem. LG argued that channel-capacity reservation rules, infrastructure-sharing mandates, compulsory carriage requirements and cross-holding restrictions were designed for platforms constrained by scarce resources such as cable bandwidth and satellite transponders. Since ALTD services operate over the open internet, the company said such requirements are technologically and legally inappropriate. It also argued for unrestricted foreign investment and automatic renewal mechanisms with only nominal administrative fees.

MAIT likewise argued that infrastructure-sharing requirements are of little relevance to the ALTD ecosystem because platforms rely on proprietary software architectures rather than common physical infrastructure. The group also raised concerns about intellectual property protection and platform security if such obligations were imposed.

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