Convergence of broadcasting and the internet demands regulatory parity without stifling innovation. Critically examine TRAI's recommended framework for Application-based Linear Television Distribution services.

Because of convergence, the same linear TV channel now reaches a smart TV through cable, DTH or an app. The Ministry of Information and Broadcasting sent TRAI a reference in December 2025. In response, TRAI recommended a light-touch Application-based Linear Television Distribution (ALTD) authorisation, which includes FAST services, under Section 3(1)(a), Telecommunications Act, 2023 [1]. The framework gets innovation largely right, but parity is still incomplete.

Strengths: Enabling Innovation with Accountability

• Low entry barriers: ₹10,000 processing fee and ₹1 lakh entry fee. There is no authorisation fee, bank guarantee or security deposit, and validity is 20 years with a single national service area [1].
• Ease of doing business: authorisation, channel registration and reporting all run through one online portal [1].
• Legal certainty: the terms are to be notified as Rules under Section 56, in line with the wider broadcasting authorisation framework [1][2].
• Content accountability: ALTD apps may carry only Centre-approved channels. OEMs and OS providers also get obligations, and ALTD viewership enters TV audience measurement [1].

Weaknesses: Gaps in Parity and Safeguards

• Fee asymmetry: DTH pays 8% of AGR and gives a bank guarantee of at least ₹5 crore. TRAI's proposed cut of this fee to zero after FY 2026-27 has not yet been notified [2].
• Three rulebooks: cable falls under the 1995 Cable Act, OTT under MeitY's IT Rules, and ALTD under the 2023 Act. The Parliamentary Standing Committee has already flagged "differential content standards" between cable and OTT [3].
• Social-media loophole: intermediary live streams are excluded from ALTD [1]. Because intermediaries enjoy safe harbour, content blocked on a regulated platform can still stream on social media [4].
• Free-speech risk: pre-approval without clear Article 19(2) grounds or an appeal route repeats PRS's critique of the draft Broadcasting Bill, 2023 [4].
• Content access: broadcaster-owned apps are excluded [1], so dominant broadcasters can withhold popular channels from rival apps. The Committee has urged MIB to make broadcasters offer their content on all platforms [3].
• Recommendatory only: under Section 11(1)(a), TRAI Act, nothing is binding until the Rules are notified [1].

The ALTD framework brings internet TV under accountable law while keeping entry cheap, which is a sound base for convergence. The way forward has four parts:

• write Article 19(2)-based refusal grounds and an appeal route into the Section 56 Rules;
• notify the DTH fee cut;
• require broadcasters to make their channels available on all platforms;
• coordinate MIB and MeitY under a single Broadcasting Services law.

Together these would deliver technology-neutral parity without stifling innovation.