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Stakeholders are requested to furnish their written comments by 16
th
August, 2024 and
counter- comments by 23
rd
August, 2024 to Shri Amit Sharma, Advisor (Finance &
Economic Analysis), TRAI. Comments and counter-comments would be posted on
TRAI’s website www.trai.gov.in. The comments and counter-comments may also be
(F&EA) may be contacted at Tel. No. +91 11 20907772.
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Contents
Chapter No.
Chapter Name
Page No
1.
Introduction of Consultation
4-6
2.
Scope of Consultation
7-11
3.
Issues for Consultation
12
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Chapter 1: Introduction
1.1 The Telecom Regulatory Authority of India (“TRAI”/ “Authority”)
was established under the Telecom Regulatory Authority of India
Act, 1997
(“Act”) to, inter alia, protect the interests of consumers of
the telecom sector. To this effect, TRAI has been mandated to
regulate tariff for telecommunication sector in India. Section 11(2)
of the Act provides,
“Notwithstanding anything contained in the Indian Telegraph Act,
1885 (13 of 1885), the Authority may, from time to time, by order,
notify in the Official Gazette the rates at which the
telecommunication services within India and outside India shall be
provided under this Act including the rates at which messages shall
be transmitted to any country outside India:
Provided that the Authority may notify different rates for different
persons for similar telecommunications services and where different
rates are fixed as aforesaid the Authority shall record the reason
therefor.”
Further, Section 11(4) of the Act also mandates that,
“the Authority
shall ensure transparency while exercising its powers and
discharging its functions.”
1.2 The Authority issued the Telecom Consumers Protection Regulations
(TCPR), 2012 (2 of 2012)
1
on 6th January 2012 to bring transparency
and help consumers understand various tariff plans. These regulations
also ensure that consumers receive information after the activation of
vouchers. To keep up with changing scenarios and market situations,
Telecom Consumers Protection Regulations (TCPR) 2012 has been
amended Eleven times since its inception.
1.3 The Key definitions of vouchers as outlined under Chapter II
(Presentation and Marketing of Vouchers)
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of the Telecom Consumers
1
Source: https://www.trai.gov.in/sites/default/files/CA_06012012.pdf
2
Source: https://www.trai.gov.in/sites/default/files/CA_06012012.pdf
5
Protection Regulations (TCPR) 2012 are as follows:
Vouchers----"(1) Every service provider shall ensure that only
the following vouchers are offered or marketed or sold to the
consumers, namely: -
(a) Plan Voucher
(b) Top Up Voucher
(c) Special Tariff Voucher
(d) Combo Vouchers”
Definition/components of various vouchers:
(a) Plan Voucher means a paper voucher or electronic
voucher that enrols a consumer into a tariff plan.
(b) Top Up Voucher means a paper voucher or an electronic
voucher providing additional monetary value to the prepaid
consumer without any restriction in terms of validity or usage.
(c) Special Tariff Voucher means a paper voucher or
electronic voucher, which on activation alters one or more items
of applicable tariff in the consumer tariff plan for a period not
exceeding ninety days in terms of limited or unlimited usage of
voice calls, SMS or data but does not provide any monetary
value.
(d) Combo Voucher means a paper voucher or electronic
voucher which on activation alters one or more items, for a
period not exceeding ninety days, in the tariff plan of the
consumer and adds monetary value to the prepaid account of
the subscriber.
1.4 The telecommunications sector has undergone remarkable changes,
with service providers increasingly offering bundled services, which
combine various products such as voice, SMS, data, and digital
content into a single package.
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Chapter 2: Scope of Consultation
2.1 Vouchers are essential instruments that provide consumers with
access to various telecommunication services, including voice calls,
data, messaging, and more. However, the effectiveness and
consumer-friendliness of these vouchers can significantly impact
user satisfaction and overall experience. In this consultation paper,
we delve into several key areas concerning vouchers, aiming to
address existing challenges to enhance the consumer experience.
2.2
Choice of Tariff Availability:
2.2.1 Telecom service providers play a critical role in offering tariff plans
that cater to the diverse needs and preferences of consumers.
However, there is a growing demand from certain segments of the
population from various channels for more specialized tariff options,
such as voice and SMS only packs. Despite the prevalence of
bundled plans that include both data and voice & SMS services,
many consumers find themselves paying for data they do not use.
2.2.2 In this context, TRAI commissioned a consumer survey to find out
the consumer preferences on the various tariff offerings. Based on
the feedback received from consumer survey, it is noticed that tariff
offers available in market are broadly bundled tariff offerings having
mix of voice, Data, SMS and OTT services etc. which may not fulfill
the requirements of large number of subscribers as all services may
not be required by all subscribers and there is a perception that
subscribers are being made to pay for services that are not required
by them. Besides, there is a perception among consumers that the
bundled offerings of telecom services act as a constraint on the
choice of subscription of telecom tariff offers by the subscribers.
2.2.3 This consultation paper intends to explore the requirement of
introducing product specific (Voice/SMS/Data and combinations
thereof) tariff offerings in addition to present tariff offerings and
make required changes in the current tariff regulatory framework.
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2.2.4 A review of international practices shows that Banglalink, a telecom
service provider in Bangladesh, offers voice-only and SMS only packs
for their subscribers
3
. Grameenphone, another telecom service
provider in Bangladesh also offers voice-only
4
and SMS only packs
5
for different validity periods. Tello, a telecom service provider in
United States, offers a tariff plan with custom choice of minute units
and free SMS packs for their subscribers
6
. Telenor, a telecom service
provider in Pakistan, offers voice-only and SMS-only packs
7
.Ufone,
another telecom service provider in Pakistan offers tariffs for voice-
only services
8
, and combination of voice and SMS services
9
.
NowMobile, a telecom service provider in United Kingdom, offers a
combination of voice and SMS services
10
. GOMO by Singtel, a
leading telecom service provider in Singapore, offers additional
packs for talk time and SMS
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. These add-on packs are designed for
customers who need more call minutes or text messages after their
main plan's allowance is used up. This flexibility allows users to
customize their service based on their individual needs, ensuring
they stay connected without overpaying for features they don't use.
2.2.5 In United states, a survey
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found that 96% of those aged 18 to 29
own a smartphone compared with 61% of those 65 and older,
reflecting a 35-percentage point difference. The trend could be similar
in India also. Therefore, introducing voice and SMS only tariff plans
in the market could provide more options tailored to the needs of
similar consumers.
3
Source: Banglalink website - https://www.banglalink.net/en/prepaid/voice
4
Source: Grameenphone website - https://www.grameenphone.com/personal/plans-offers/offers#voice
5
Source: https://www.allsimofferbd.com/2019/08/gp-sms-pack.html
6
Source: Tello website - https://tello.com/buy/custom_plans
7
Source: Telenor Pakistan website - https://www.telenor.com.pk/post-paid/call-bundles/
8
Source: Ufone website - https://www.ufone.com/offers/
9
Source: Ufone website - https://www.ufone.com/voice-sms-buckets/
10
Source: Nowmobile website- https://nowmobile.co.uk/sim-only-deals/monthly
11
Source: GOMO by Singtel website- https://gomo.sg/idd
12
Source: https://www.pewresearch.org/short-reads/2022/01/13/share-of-those-65-and-older-who-are-tech-users-has-grown-in-the-past-
decade/
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2.3 Validity of Vouchers:
2.3.1 Various stakeholders have expressed a strong preference for
extending the validity period of Special Tariff Vouchers (STVs) and
Combo Vouchers (CVs) beyond the current 90-day limit. This
extension would allow for the creation of packages with longer validity
periods, addressing the needs of a diverse customer base.
2.3.2 A consumer survey to find out the consumer preferences on the
various tariff offerings conducted by TRAI has highlighted that
subscribers overwhelmingly favour vouchers with extended validity.
The primary reason cited by subscribers is the desire to avoid the
inconvenience of frequent recharges, which disrupts their service
experience and creates unnecessary complexity in managing their
mobile accounts.
In the light of the foregoing discussion, the following questions arise
for consultation.
QUESTIONS FOR CONSULTATION
Question 1: How do current tariff plans offered by telecom
service providers align with the preferences and usage
patterns of consumers, particularly elderly individuals? Please
Justify with rationale.
Question 2: Is there a need for separate plans for Voice & SMS
and data to meet the specific requirements of subscribers.
Please justify with reasons.
Question 3: Whether the maximum validity of Special Tariff
Vouchers (STVs) and Combo Vouchers (CVs) should be
increased? Please Justify your response with reasons.
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2.4
Colour Coding of Vouchers:
2.4.1 To facilitate easy identification of vouchers by the consumers, a colour
band code was introduced on the reverse of the vouchers to distinguish
different types of vouchers.
2.4.2 To ensure that subscribers can easily distinguish between different
types of Vouchers (Plan Vouchers, Special Tariff Vouchers, Combo
Vouchers, and Top-Up Vouchers)
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, following color-coding system was
introduced:
– Red colour band for Paper Plan Voucher
–
Green colour band for Paper Top Up Voucher
–
Yellow colour band for Paper Special Tariff Voucher
–
Blue colour band for Paper Combo Vouchers
2.4.3 With the changing market dynamics, the physical vouchers are on a
decline in the market. As a general practice, dealers are also doing
recharge online instead of selling physical vouchers. There seems to be
a case of revisiting the provision of colour coding of various vouchers.
2.4.4 The need to evolve these practices into digital formats is becoming
increasingly apparent. In the digital era, the functionality of colour
coding can be seamlessly integrated into electronic systems. Digital
colour coding can offer the same benefits as physical vouchers.
In the light of the foregoing discussion, the following questions arise
for consultation.
QUESTIONS FOR CONSULTATION
Question 1: In the current scenario, where dealers are doing
recharge of vouchers online instead of selling physical
vouchers. How relevant is colour coding of physical vouchers?
Please justify with reasons.
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Source: https://www.trai.gov.in/sites/default/files/CA_06012012.pdf
10
Question 2: Whether colour coding can be introduced in
digital mode to enhance consumer convenience and clarity?
Please justify your response.
2.5
Denomination of vouchers
:
2.5.1 The existing policy mandates that only Top-up vouchers are permitted in
denomination of ten rupees and multiple thereof, while Special Tariff
Vouchers (STV) and Plan Vouchers (PV) cannot be offered in the
denomination of ten rupees and multiples thereof
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. Since Top-up voucher
offers only monetary value without any restriction in terms of validity or
usage, a differentiation was made to make them distinguishable by
subscriber by reserving denomination of rupees ten and multiples thereof for
these vouchers.
2.5.2 As pointed out by various stakeholders, given the current market dynamics
and the recharges of vouchers done through digital mode, there is a case to
review that only top-up vouchers are available in denominations of Rupees
Ten and multiples thereof while other vouchers are not available in
denomination of Rupees Ten and multiples thereof.
In the light of the foregoing discussion, the following questions arise for
consultation.
QUESTIONS FOR CONSULTATION
Question 1: In the present situation where recharge of vouchers is
carried out through digital mode, is there any relevance of
reserving denomination of Rupees Ten and multiple thereof only for
Top up Vouchers. Please Justify with reasons.
Question 2: Whether all types of vouchers can be allowed to be
offered in any denomination of the choice of service provider?
Please Justify along with rationale.
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Source: https://www.trai.gov.in/sites/default/files/CA_06012012.pdf
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Chapter 3: Issues for consultation
Question 1: How do current tariff plans offered by telecom
service providers align with the preferences and usage
patterns of consumers, particularly elderly individuals? Please
Justify with rationale.
Question 2: Is there a need for separate plans for Voice & SMS
and data to meet the specific requirements of subscribers.
Please justify with reasons.
Question 3: Whether the maximum validity of Special Tariff
Vouchers (STVs) and Combo Vouchers (CVs) for consumers
should be increased? Please Justify your response with
reasons.
Question 4: Are there specific consumer segments that would
benefit from longer validity periods for Special Tariff Vouchers
(STVs) and Combo Vouchers (CVs)? Please Justify along with
rationale.
Question 5: In the current scenario, where dealers are doing
recharge of vouchers online instead of selling physical
vouchers. How relevant is colour coding of physical vouchers?
Please justify with reasons.
Question 6: Whether colour coding can be introduced in
digital mode to enhance consumer convenience and clarity?
Please Justify your response with rationale.
Question 7: In the present situation where recharge of
vouchers is carried out through digital mode, is there any
relevance of reserving denomination of Rupees Ten and
multiple thereof only for Top up Vouchers. Please Justify with
reasons.
Question 8: Whether all types of vouchers can be allowed to
be offered in any denomination of the choice of service
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provider? Please Justify along with rationale.
