DoT’s Re-vision to the OSP framework

Background

On 23 June 2021, the Department of Telecommunications (DoT) issued the Revised Other Service Provider (OSP) Guidelines (Revised Guidelines), in supersession of the New OSP Guidelines that were released on 5 November 2020 (Old Guidelines).

The Revised Guidelines define an OSP as an entity that provides voice-based Business Process Outsourcing (BPO) services to customers located world-wide, including in India. Voice based BPO services means call centre services, where customers access the network of OSP through public switched telephone network (PSTN). The distinction between international and domestic OSP in the Old Guidelines has been done away with.

One of the objectives of the Revised Guidelines is to ensure that toll-bypass does not take place. Toll bypass means transmission of PSTN calls, be it between India and foreign country or between two cities in India, using own network of an OSP. It appears that “own network” referred to in the definition, means a private network like MPLS. The definition of toll bypass and the dispensations explained below should ideally be read harmoniously, although no such indication is provided by DoT.

An OSP centre means a location in India where infrastructure of an OSP is placed. This is a very important definition. In case EPABX is not installed in an OSP centre, the remote access to all CDRs, system logs, configurations of EPABX have to be made available to DoT from an OSP centre in India. 

Dispensations for OSPs

Under the Revised Guidelines, OSPs have been provided certain exemptions from general telecom regulatory requirements and it will be important to understand them. These are as follows:

Foreign EPABX and Distributed Architecture for EPABX

Work from home

As was the case in the Old Guidelines, the Revised Guidelines still require a remote agent to connect to the OSP centre, which can be over broadband (wirelines or wireless). Therefore, it can be said that connection of a remote agent through mobile network i.e. PLMN will not be permitted. However, it is now permitted that the OSP agent can also directly connect to the centralised EPABX or EPABX of the OSP or even EPABX of the customer. The permission to connect to the EPABX of customer could be to avoid double hopping. However, remote access to CDR, system logs and EPABX configuration are required at one of the OSP centres. 

Comment

It is commendable that DoT has issued the Revised Guidelines barely within 7 months of the last revision in November 2020. This reinforces the DoT’s intent to support the cause of ease of business. To accommodate the industry demands, instead of publishing FAQs, DoT has released these new guidelines, which in a way has led to further liberalisation. There is clearly an effort to further simplify the OSP framework by defining important terms including voice based BPO services, toll bypass, CDR/UDR, System logs.

That said, some definitions (like that of ‘toll bypass’) could have been further simplified by adding some illustrations and examples. Further clarity on issues such as use of cloud/hosted contact centres and placement of EPABX outside India for domestic call scenarios would be beneficial for the industry. 

It will be interesting to watch this space as in due course it is expected that new concepts and models will emerge for OSPs.

-         Harsh Walia (Partner) and Shobhit Chandra (Principal Associate)

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