Unsolicited Commercial Communications Regulation in India– Trigger for Mobile Based Advertisement

The online advertisement spend by advertisers are reached INR 2260 Cr ending March 2013. The market size is too low. The advertiser’s prefer to opt for telemarketing and promotional SMS to reach out to Mobility user compared to application based mobile advertisement on mobile. The Applications ecosystem in India is not matured enough to offer hidden potential of device centric and application hosted mobile advertisement due to number of reasons such as backend delivery, Contextual capture, mobile e-Commerce mechanism. The lack of technology supported triggered advertisers to choose telemarketing and promotional SMS to offer product awareness drive through the mentioned media. In order to keep the cost low and offer better value proposition, many telemarketing and bulk advertisement providers decided to choose short cuts to capture market share. The move turned out to be risk for consumer privacy, content security. Post multiple regulatory directives, regulators failed to stop pesky telemarketing calls and SMS by telemarketing companies. In order to control unaccounted billions of message routing through illegal mechanism prompted regulators to put the onus on Wireless operators to enhance their network to eradicate or control revenue leakage which is impacting whole ecosystem player. Post few high voltage meetings and directives, it is observed that many companies indulged in Mobile Marketing using Telemarketing and SMS experienced drastic fall in their order flow and business. Any positive impact of unsolicited commercial communication regulation would force advertisers to find another medium to reach out to consumer base. With the growing adoption of Application among Indian medium to high end smartphone users, Mobile marketing business is going to be redirected to Mobile advertisement based marketing. In my earlier post, I mentioned about Mobile based advertisement market size of INR 230 Cr but I can see that $ Bn’s opportunity is waiting for the smart companies to capture.

Indian Mobile Marketing Business experiencing fall in business post stringent regulation

The regulatory effort to protect Indian wireless and wired subscriber privacy as well as to enforce regulation started to show positive impact after 5 years of effort. In recent months, Indian regulators warned few wireless operators to twist their networks identify, block and initiate action against telemarketing flaunting regulatory compliance forced Mobile marketing tools as well as service provider to remodel their service offering. The “Telemarketing and SMS based promotional activities are termed as Wireless Enterprise Mobility” by few service providers raised their concerns regarding fall in business post enforcement of Do not Disturb, Increased termination charges and termed regulatory moves as showstopper act. I am surprised to observe that none talked about consumer pain and overall benefit of regulation on wireless ecosystem. I also carry reservation in terming Telemarketing calls and SMS based promotional calls as wireless marketing because all kind of wireless service must be supported with subscriber consent. The current solution offerings neglect consumer side.

Indian User Opinion about Pesky Calls and SMS – Lack of Awareness and Social Responsibility Adherence

Recent weeks print media is full of articles around pesky calls and SMS monster which is taking centre stage in most not all communications from regulators. Regulators are proposing stringent fines across ecosystem players involved in supporting pesky calls and SMS. Post multiple blog article posted by me on different social sites to professional sites to increase awareness about negative impact of pesky call and SMS engineering, I realised that Indian subscribers are least bothered about happening around them. I thought of another approach to figure out the unsuccessful enforcement of regulation and esteemed Indian subscribers opinion about the same. Post talking with more than 200 very educated, professionally successful, well-known names in their respective sectors; I reached to the following conclusion

• Not aware of processes to take on pesky caller and SMS originator
• No one want to get into legal process
• Even NDNC subscriber told that nothing is going to improve so it’s useless to talk about it
• No one ever launched any complaint but proudly admitted that they are getting multiple calls and SMS on daily basis
• Other few opinion were very crude and prefer not to share the same

If Industry especially Telco’s are losing Billions of $ then Telco must be part and parcel of awareness program. At the same time, there must be participation by corporate world to increase awareness among their employee about the Pro’s and Con’s of pesky calls and SMS on personal and professional information management. Government may consider stringent information technology centric regulation and announce heavy penalty on companies giving business to mass product marketing companies without adhering to government regulation.

Average pesky call and SMS complaint by registered user per month is too low to deter illegal players

Telecom State Minister came out with average monthly complaint rate against illegal telemarketers and SMS spammers. The number quoted by honourable minister was “27760”. For normal citizen of India, any attempt by subscribers to complain against pesky calls or SMS during assessment, the current scenario is completely different. If 161 Mn plus registered NDNC users are only sending above mentioned number then we must accept the fact that any news report on different print media is completely exaggerated, Isn’t it? It depicts that only fraction of percentage of NDNC users are filing complaint. I believe government regulators must have done analysis better than us and must be worried that how pesky calls and SMS spamming is going out of hand. The sooner we wake up, the better it would be for country. Post survey, the conclusion is very Simple ‘NDNC does not work and its hopeless service. Being a user, I am going to pick up call from Unrecognized calling number” The approach is escapist one not head on approach. We need to take on the issues head on instead of taking back seat.

Pesky calls and SMS issue in India can be resolved through Social responsibility act only – Act before it hit your information

Recently, TRAI got very active to completely eradicate pesky calls and SMS to offer and protect privacy of Indian subscribers. TRAI came out with 11^th amendment around unsolicited commercial communications to send across warning bells within service ecosystem. According to Newspaper Hindu Business line article Tata- Tele, Reliance Communications and Aircel were served warning from regulators to make all necessary arrangement to monitor pesky calls and SMS generation through their network by rouge telemarketers and SMS service providers. Two years back Bharti Airtel stopped their bulk SMS service to offer privacy and QoS of their subscribers but unfortunately the big three of Indian Telecom sector Bharti Airtel, Idea and Vodafone India suffering the most because of their subscriber target base.

In another report in Economic Times, the new mechanism of bulk flooding of SMS using GSM Modem attached 100’s of SMS SIM’s and every SIM are calibrated to send only TRAI limit of daily SMS.

Important to Note that, the above mentioned process of acquiring 100’s of SIM for commercial purpose highlight major security flaws in the verification process of subscribers. It raises following questions and believe that being citizen, subscribers, Enterprise and service provider, we all should take 2 min to think about it

1. How rouge players are managing to acquire so many SIM’s?
2. Is there any flaws in SIM and Subscriber authentication process or
3. Who is giving rouge player’s business for Telemarketing?
4. Are regulators focusing in penalizing advertisers to use rouge players?
5. Is it effective to disconnect mobility connection and bar particular subscriber for 2 years?

In my point of view, the advertisers and pesky calls and SMS providers must be penalized heavily to start with.

Request reader to own up social responsibility and share article to increase awareness among our innocent subscriber base. If we all want to see India growing through differentiated approach, then we all must be united the way we follow when there is any threat on our boarders. Thanks in advance for your

Serious attempts by Department of Telecommunications, India to control pesky calls – Considering Imposing Heavy Fines for Each pesky calls

Department of Telecommunication, India tried all methodology to control pesky call and SMS to offer privacy to subscribers. Even service providers invested millions of $ to upgrade their network attached system   to tackle the nuisance of pesky calls and SMS to their esteemed customer base.The end losers are service providers as they are struggling to shore up customer QoS and Privacy clause. The recent flurry of high level  meeting in DoT and TRAI followed by the head of Service provider meeting with regulator got everyone into action.The TRAI directives to service providers to refine network KPI’s to identify and block pesky and SMS seems very difficult as the illegal pesky caller and bulk SMS providers are one step ahead in thinking to find the weak spot of the network to bypass the monitoring tools.The P&G department requested feedback on right to privacy bill from DoT and proposed to slap 20K INR for every ICC calls by telemarketers.The department is also considering intercepting to phone calls in order to establish the phones calls from telemarketers to end subscribers

The department is also considering blacklisting and UCC caller won’t be able to own mobile connection for 2 years.It would be interesting to see “what mechanism TRAI and Service Providers” would propose to eradicate billions of UCC messages and calls from network.

I can only offer best wishes to BFSI, Real Estate sector as that sector would be hit hard. Also the highlighted issues by Service providers and DoT are only 10% of the existing concerns around pesky calls and SMS.

One Nation –One License -Free Roaming Policy offer India Full MNP vision achievement

In approved NTP 12 document, the Indian government clearly stated long term vision for telecom sector - to exploit the already built foundation to create unprecedented communication reach across Indian geographies. It also set very aggressive targets on teledensity, potential network deployments to serve and offer Indian people very cost effective communications services.

I have already highlighted in my earlier blog posts, MNPRegulation – Regulator’s Vision Verses Reality and UnrealisticNational Telecom Policy vision to achieve 70% Teledensity by 2017 & 100% by2020, the current pattern of broadband and logical challenges in achieving the set goal by the government. But the most interesting vision is to

1. Strive to create One Nation - One License across services and service areas.
2. Achieve One Nation - Full Mobile Number Portability and work towards One Nation -Free Roaming.

The above mentioned clause took telecommunication service providers by surprise and it is even more surprising when there was lack of visibility on the licensing issues.

Currently, Two MNPO’s are managing dipping database and service providers in the respective zones and are integrating their networks through centralized database development to get the real time update.

In a current scenario, the mobile user can only make donor to receipt mobile operator switch within their current service geography or circle.

Is there a need of “Full MNP” when one license across services and service area is going to be implemented?

In a scenario of national roaming abolishment; Intra circle roaming would be abolished and all operator level switch would not be limited to specific circle level. Once intra circle level roaming under one license regime comes into force, it would automatically enable ported out user free movement and flexibility of keeping same MSISDN across service geography. It would automatically offer full MNP across recipient’s mobile operators’ service geographies.

The mobile operators would be forced to pay carriage fee in order to correctly connect and deliver voice call and SMS respectively. On the capex and opex front, the Mobile Operator’s, International Long Distance Operator’s would be forced to remodel centralized ported user database, SMS aggregation platform as well as realign their service logic and business logic in order to correctly redirect voice and SMS traffic. I have not seen any updated regulatory document about the changes required to be done on the dipping database update side.

Even more surprising that regulator are in consultation with stakeholders, post deciding on the policy without zeroing in on the licensing, potential solutioning impact on the user and network performance and cost attached with it.

In my point of view, free roaming would remove the need of Full MNP. The existing mechanism of limited MNP would automatically be extended to Full MNP. The regulators may opt for the clear specifications defining all the raised concerned points by the stakeholders to reduce the revenue loss fear and associated cost. The consultation regarding the licenses and associated cost, post policy approval is bit surprising. I must stress that there are multiple hidden business opportunities for ecosystem stakeholders out of the unwarranted challenges around Full MNP and free roaming.

Growth Opportunities in Indian Mobile Operator Segment

The MVAS, UCC, User verification norms based regulation is hurting VAS revenue for the last six to eight quarters. The regulations clearly impacted SMS and IVR based VAS services and products. The mobility messaging and other VAS revenue share came down from 10-11 % (Q4, FY12) to around 8% (Q3,FY13, consolidated one) whereas data revenue reached to 6-7% (Q3, FY13) from 3% (Q4, FY12). Moving forward, Mobility industry would experience further negative growth in high single digit QoQ for next few quarters reflecting the regulation clause of getting the authorization from user before activating MVAS services. Any authorization process based on IVR, SMS or email may experience low adoption by the consumer due to multiple surrounded reasons. It would clearly impact on Messaging, IVR, Music, RBT, ODV and SMS based delivered, activated Applications. The expected market size of total and non-voice mobility market size may touch $ 32 Bn & $ 5.7Bn (including data and other services). On-going revenue trend suggest that Mobile operators may be able to generate close to $ 2.3Bn from data services neutralizing the loss of MVAS revenue share. According to TRAI performance indicator report, 49% of the total mobile user devices are data capable and that translate it to 440Mn pulse potential total addressable market. With the current paid data user base of around 140 Mn generating slightly lower $1 ARPU present great opportunity to convert lost revenue opportunity into new revenues. Based on the numbers and trend, Mobile operators are losing more revenue than generating. With the population base of 65% as youth, opportunities are offered for mobile operators for smooth transition from SMS, IVR & Voice based and dominated MVAS to data centric MVAS services. The MNO’s are actively refining and defining their evolving delivery mechanism to make it interoperable, portable, and secured through cloud centric and OffNet/OnNet supported environment to capture the un-captured.

The super hyped 3G & BWA - $13 Bn in license auction and another $ 10 Bn in network upgrade investment stretched service providers balance sheet to the limit and their 30% EBITA is used to service debt burden. The slow 3G service user acquisition which stands at around 30 Mn worsened the situation. In the BWA segment only few operators are able to launch their services. Most of the observer started writing down India 3G story as none of the mobile operator covers all circles and regulatory/legal dispute on 3G roaming. It might have dented user confidence to opt for the service. In India, only 8-9% of the total mobile users are frequent travellers and would require seamless roaming. I believe strongly that slow adoption will gather pace with the higher adoption of enabled handset, lower cost through cutting edge delivery platform. The dedicated and priority based QoS, security, data protection, online storage space and dynamic charging model would attract more and more user base. The recent data revenue and user growth is going to act as catalyst for ecosystem players to focus on data centric services, product or application development instead of focussing on auto cycled legacy MVAS product line. The paid applications download is going to experience high double digit growth QoQ for next few years from current run rate of 7-8 million download per month. In my opinion, the incumbent mobile operators must create and invest heavily on new product development research and development to keep on fulfilling user adoption and usage trend pattern quickly instead of relying on MVAS players’ product lines. The mobile operators can easily invest by reducing advertisement cost by 2% as mobile operators at an average invest 10% of their revenue on advertisement. The continuous investment on brand building by most of the mobile operators for the last 10 years created an environment where these brands are household name and thus now they can afford to reconsider their strategy on advertisement investment cut

The innovative services offering product lines to manage Consumer and Prosumer VAS across connected device environment would kick-start VAS revenue growth. The realignment of consolidated SDP into multiple virtual service delivery platforms is needed in order to cater voice, data and video centric VAS portfolio. It would enhance the QoS w.r.t service creation, execution, activation and provisioning. It would also offer granularity in B2B and B2C usage mirroring, higher renewals and increase user adoption.

Impact of Multiple Toll Free Numbers, Short Codes & Portals for UCC, Telemarketing, MVAS, Data, MNP

The most annoying aspect of MVAS user base is to keep getting IVR, SMS initiated promotional campaign by MNO’s, VAS provider and Enterprises. This has triggered more and more MVAS user opting for DNC directory registration. The continuous attempt and failure to stop unwarranted activities by ecosystem prompted regulators to come out with regulatory directive implementation to reduce mobile user pain points.

For UCC, the NDNC mobile users are supposed to call back on paid customer service of mobile operator to provide the details of UCC. Post launching complaint, mobile users get ticket number with a promise that they will not be getting UCC message after 4 business days and mobile operators’ customer support team will validate the same post deadline date.

Alternatively (Ref http://www.nccptrai.gov.in/nccpregistry/Welcome.jsp?EIID=null ) customer must send SMS to 1909 by following the format "the unsolicited commercial communication, XXXXXXXXXX, dd/mm/yy". Where XXXXXXXXXX - is the telephone number or header of the SMS, from which the UCC has originated. The telephone number or header and the date of receipt of the unsolicited commercial SMS may be appended with such SMS, while forwarding to 1909, with or without space after comma.

In a similar fashion, unwarranted MVAS deactivation process include mobile user calling IVR supported and guided toll free number 155223. The system identifies called number, maps it with the any activated MVAS services and subsequently execute customer request.

For MNP, each mobile operators launch different toll free number series with 1800. The mobile user needs to visit MNP status section of foreign network to check the status of their porting request.

For any information regarding new service, MVAS, Billing status, the mobile user need to call 121 or 111 or other allocated numbers.

The multiple information points, complaint numbers, toll free numbers are not adding value but confusions for mobile consumer base. It’s a human nature that single click service always gets higher adoption.

It raises more queries than answer viz.

1.  When UCC regulatory solution is already implemented then why mobile users are still receiving UCC. It is very common to hear from service provider that they are not allowing any UCC initiating from home network whereas cannot control the same when UCC is directed from foreign network. It shows that either customer service professionals are not trained properly or not willing to accept the gap in the network.
2. Isn’t it possible to block MSISDN initiated UCC messages at network level? The UCC complaint directives and subsequent release of number of complaints confirms that there are gaps in the directives or network levels
3. What are the mechanisms used to check the content of an UCC to validate if the regulatory directives are followed? For example, the limit of 200 SMS per day are being misused to  flood UCC and based on the current state, it is very clear that there are gaps in correlating information from NDNC dipping server, Content filtering, Security and White/black listing of MSISDN.
4. Is there any monitoring tools implemented to scan SMPP based messages and accordingly to block illegal traffic?
5. If SMS is used to get the confirmation from mobile user for the authorization to activate MVAS for any new services then the mobile operators may also opt the same process to take the authorization for existing running MVAS. It is hard to understand why mobile users are accountable to initiate the process to deactivate existing services
6. Is it difficult to create consolidated portal and single toll free for MNP, with hierarchical administrator management functionality, offering mobile user to select from the list of all service providers with service area and opt for foreign network?
7. Is it mandatory under any clause of regulatory directives that service providers must offer different toll free number or can consolidate under one toll free number? In my knowledge that’s not the case
8. Isn’t it really difficult for most of the mobile user to maintain all Toll free number? Many consumer and prosumer don’t even know on going initiative by service providers or regulatory body
9. Generally, its consumer and prosumer tendency to ignore bothering SMS and OBD based promotional calls but it should not be ignored given the growing security threats towards mobile devices. According to TNN research the 'Malware attacks on mobiles went up 122% in 2012 compared to 2011’. The research outcome also demonstrates the hidden threat towards user device, data including financial information.

Consolidation of all authorization, activation, deactivation, and complaint across UCC, Telemarketing, MVAS, MNP and integrating it with existing or new portal is going to reduce cost as well as increase awareness among userbase.

In conclusion, the current scenario is creating complex environment for consumer to launch their complaints. It is impacting negatively on mobile operator O&M cost structure and subsequently high TCS (total cost of service) per consumer. The streamlined consolidated single portal, single Toll free number across mobile operators’ network which can be owned by mutually agreed third party will result in quick resolution of consumer pain. The move would be a win-win situation for service provider to comply with regulation by sharing the cost of management of portal. In a scary upsurge of security threats towards mobile devices, all of us should come forward to raise concern. Any negligence can be used as entry point by hackers.

MNP Regulation – Regulator’s Vision Verses Reality

In 2009, Indian regulators came out with ambitious regulation to enforce Mobile Number Portability. The vision was centric to number series, network performance, infrastructure control, security, consumers, and competitiveness. In order to make the process quick, the regulators divided Indian geographies in two zones and appointed MNP operator to manage the MNP database. The regulation also included the stringent conditions to access MNP database to mitigate any leakage on consumer data. It also included a clause that any telecom centric service provider must host all infrastructures in India and won’t be allowed to carry out any processes related to MNP data outside India. In order to handle international traffic on the voice and SMS side, ILDOs were asked to install additional infrastructure to direct, redirect voice and SMS (complete one) to the right home network of ported mobile subscriber. The regulators also fixed the porting charges of $0.35 from mobile subscriber to offer the parity.

The regulations forced mobile operators and international long distance operator to invest millions to accommodate expected changes on the subscriber awareness, network, reporting, billing, bilateral agreements and additional resources to execute MNP porting request by subscribers.

The subscriber accountability was nothing but cleared dues in order to opt for the porting request from home to foreign network.

In an environment of stiff competition, tariff wars initiated by new entrants, subscriber acquisition and retention war acted as a blow for all mobile operators.

As of now around 78 million mobile subscribers opted for porting request and in my point of view most of them negotiated free call minutes and SMS as selection criteria to choose new home network. The Circle B and C observed maximum porting request where new entrants launched their services and offered free calling within home network to attract potential subscribers opting for MNP. The indirect user acquisition mode, initiated by new entrant, forced incumbent mobile operator to offer freebees to match with the competitor to retain their subscriber base. The unexpected dynamics impacted new entrant and incumbent mobile operators with low realization of ARPM (Average revenue per minute) and low messaging/VAS revenue.

It is expected that with the rise of tariff by incumbent and reduced freebees, the subscriber flip flop strategy to get the minimum bill will fail.

As against the regulators vision of creating QoS (Quality of Service), security and fair competition as major parameter, subscriber opted for MNP considering low billing, high usage offer.

In my opinion, the regulators must also make subscriber accountable where subscribers must offer valid and authenticated reasoning to opt for the porting service to foreign mobile network. In case, subscriber fails to provide the same then they should be charged for porting to discourage subscriber to misuse regulatory propositions.

In conclusion, the mobile operators spend at an average around $ 9 to acquire a new customer and mobile operator’s interest must be protected. The mechanism must be developed to refine and define existing porting criteria for mobile subscribers. With the rise of tariff and fall of freebees, cost and utilization sensitive subscriber base would be discouraged. Moving forward I won’t be surprised if there is a drastic fall in porting request across circles

UCC and Telemarketing – Stringent Regulation & Monitoring Needed

In 2006 “Unsolicited Commercial Communication’ regulation initiation and subsequently National Do Not Call (NDNC) Registry was established in 2007. The purpose of NDNC was to enable Mobile operators dip into the database before connecting voice calls from e-marketers and forward messages to end subscriber. With further unseen problems, the regulators enforced tele-marketers to register with the regulatory body to get the NDNC dipping facility to scramble their database and match with NDNC before allowing call to non-NDNC subscriber base.

The suggested regulatory directives were fully supported with Mobile operators and NDNC cost was absorbed by mobile operators to improve the customer experience. Still Mobile operator networks are flooded with UCC and subscriber pain increased with the higher adoption of web usages. It leads to simple query regarding the failure of UCC control. With the adoption and evolution of mobile network and subscriber base, the number of business sector identified mobile marketing as a simplest mechanism to position their product given the cost verse reach factor. It brought Bulk SMS provider with short codes into picture. Many of the company started deploying Bulk SMS infrastructure with minimum or no feature set of SMS platform but got the short-code enabled with most of the mobile operators and used web-services to enable customer to launch their targeted subscriber base across Mobile operator network. In FY12, the Bulk SMS volume size crossed 25 Bn and expected to grow by 20 in FY13. In FY11, Airtel stopped Bulk SMS business and also advocated vigorously to increase Bulk SMS termination charges as mitigating factor by making Bulk SMS cost unviable in order to reduce UCC. All efforts of regulator and millions of $ investment showed no to little impact on UCC traffic volume. Detailed analysis came as rude shock as the UCC and tele-marketing turned as illegal business model by many rouge companies. They use 10 digit MSISDN number to send UCC and mention short codes as well as 10 digits MSISDN to enable interested potential mobile subscriber to get connected with the advertisers. UCC under the wrap of P2P messages goes undetected by mobile operator network and get delivered to mobile subscriber and in turn Mobile Network Operators are held accountable. Similarly, the tele-marketers are buying mobile subscriber’s number from various sources and use 10- digit MSISDN to go undetected by Mobile Operator as well as regulators.

Based on my analysis, the above mentioned activities by rouge Bulk SMS providers as well as tele marketers are inflicting major revenue loss for both Mobile Operators and Government. Under Telecom act, any message consisting of commercial information or potential of generating revenue for message sender must be considered as commercial message and cannot be treated as P2P message. Short Codes response request from subscriber P2A but in this case A2P message is missing in order to complete the cycle.

All these activities by few SMS based advertising companies for quick gain costed Mobile operators Millions as penalty from regulatory and landed them in loggerhead with regulators.

The Mobile Operators may opt for SMS aggregation platform with content monitoring, filtering and security to identify UCC and take the legal action. At the same time regulators may opt for stringent clause for companies opting of mobile advertisement based product awareness through rouge Bulk SMS providers. The companies giving a business to rouge Bulk SMS provider must be penalised so that other gets discouraged and opt for legalised Bulk SMS providers. Regulators may also opt for centralized Web Portal for both UCC and telemarketing related complaint, initiated action and end result. At the same time, the Telecom ministry should take subscriber awareness program which would lead mobile subscriber comes forward and lodge formal complaint.

In conclusion, UCC and unauthorized telemarketing is not only carrying nuisance value but also possess great threat towards mobile operator network, device security, theft of sensitive information and national security.

MVAS Regulatory– Technology and Business Impact on VAS companies

The government regulator initiative to govern VAS vendor and mobile service provider to protect end consumer needs further re-calibrations. Post consultation paper release in FY10-11 and subsequent responses from ecosystem stakeholders highlights showstopper as well as hidden opportunity around proposed MVAS. This article highlights Technological and Business continuity challenges posed towards VAS developer, Owner’s, and aggregators.

Before going into details of impact, MVAS regulation makes it mandatory for the VAS service provider’s to take authorization from end user to activate requested VAS service. Post authorization, Service Provider would be able to bill end user. The process must be repeated at the end of VAS service expiry.

The government regulatory wanted to address end user concerns of repeated billing or lengthy process of deactivating unwarranted VAS services but in-turn forced VAS ecosystem players to realign their VAS design, development and delivery mechanism

The technological and financial impact on the VAS providers would be the followings:

Technological Impact

1. All VAS provider would be enforced to change the service delivery mechanism both on the service and business logic level to support the regulation on Service Creation,Execution, Activation, QoS, Provisioning and Assurance
2. Enhanced two way Security, Business Intelligence, Reporting and Billing upgrades
3. All VAS provider would be enforced an automated customer care portal integrated with mobile operator website in order to seamless adhere regulation
4. VAS provider would be required to integrate minimum feature set of Service Delivery Platform and integrated CDN
5. All VAS provider must offer certified product or service w.r.t standardization for seamless integration with Mobile Operator Network
6. All VAS services or product must be certified across devices in order to get the security clearance from mobile operator
7. All VAS provider must have dynamic feature set with a capability of segregated and aggregated mechanism to enable and disable business and service logic based on the product offering

Financial Impact

1. Due to the high capex and opex cost by Mobile operator, there is a high probability that mobile operator would renegotiate the price point with VAS provider
2. High Capex in implementation required regulatory compliance feature set
3. High Capex in certification process
4. High Capex to upgrade VAS service or product attached  technological platform
5. Lower customer adoption and subsequent low VAS revenue due to stringent mechanism.
6. Low ARPU per customer across Apps, SMS, Data- music, video centric service
7. High Capex to offer committed QoS
8. Low RoI and High TC

In the midst of high competition, margin pressure and added hidden threats of MVAS regulation may take Indian Mobile Operator into VAS tariff war which till now was not affected with the same.

In conclusion, MVAS regulation might bring cheer for end user but High TCA, TCO, UAC and cumbersome processes would translate into Low - VAS Revenue, ARPU, Margin, RoI. It also possesses great opportunity for the innovative VAS companies to tap untapped VAS userbase.