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DoT - Revised Other Service Provider (OSP) Guidelines

On June 23, 2021, the Indian Telecom Ministry’s Department of Telecommunications (“DoT”) released a revised set of Guidelines for Other Service Providers (“OSPs”) (“New Guidelines”).

OSP regulations were significantly relaxed in November 2020 – you can read BTG’s summary of that change here. These New Guidelines replace the guidelines issued in November 2020 (“Old Guidelines”) and further simplify the regulatory framework applicable to OSPs.

A copy of the New Guidelines can be accessed here.

The New Guidelines make the following key changes:

  1. Applicability: The New Guidelines apply to OSPs that provide ‘voice-based business process outsourcing’ (BPO) services to customers located in India and abroad. This targets call center services provided by OSPs via public networks (PTSN / PLMN / ISDN) but not data-based entities that facilitate calls via voice over internet protocols (i.e. VoIP). Non-voice based BPO services are not included under the purview of the New Guidelines. This was a significant change in the Old Guidelines, that clarified that OSPs are entities providing BPO services, and not (say) an entity running a captive call center for its own customers (which latter interpretation was a source of great confusion pre-2020). The New Guidelines reiterate this more ‘targeted’ view.

  2. Domestic and International OSPs: The Old Guidelines had removed registration requirements for OSPs, and the New Guidelines further de-regulate by scrapping the distinction between domestic and international OSPs.

  3. “Toll Bypass” defined: While the previous iteration barred bypassing the jurisdiction of the International Long Distance Operator (ILDO) and National Long Distance Operator (NLDO), the New Guidelines go a step further by defining “toll bypass” as illegal carriage of voice traffic that infringes upon a telecom carrier’s activities. This should bring in more clarity in formulating call structures.

  4. Interconnection between OSPs: There are no restrictions on interconnectivity of data and voice calls between OSP centres. Since the distinction between domestic and international OSPs has been removed, interconnectivity between domestic and international OSPs will also be permitted. However, voice interconnectivity for ‘closed user groups’ is restricted to OSP centres for the same company or same group of companies.

  5. Foreign EPABX: All OSPs (including domestic) can now situate their Electronic Private Automatic Branch Exchange (EPABX) outside India. Companies will now be able to utilise their global EPABX for their call centres in India and deploy global technologies which are not accessible to EPABXs located in India.

  6. Distributed architecture: OSPs had been allowed to have a distributed architecture for their OSP centres across India, provided the OSP owned the EPABX. Such EPABXs owned by the OSPs can now be placed at third party data centres in India, and the OSPs can avail EPABX services from Telecom Service Providers.

  7. Work-from-home/anywhere: OSP agents working remotely were previously required to comply with various requirements in order to connect with the OSP centres and EPABX. The New Guidelines relax these requirements by permitting remote OSP agents to connect to the OSP centre using any technology (including broadband/wireless) and directly connect with the EPABX of the OSP/customer.

What this means for you

The New Guidelines have liberalised the regulatory framework and reduced oversight over OSPs. In particular, removal of any distinction between domestic and international OSPs will enable global companies to set up BPOs and contact centres in India and simultaneously rely on their global EPABXs. Additionally, the relaxing of restrictions on interconnectivity and distributed architecture potentially allows for knowledge sharing in a seamless manner.


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