COAI statement on ‘regulation of OTT communication applications’

Lt. Gen. Dr. S.P. Kochhar, Director General, COAI

“COAI expresses concern with the recent media reports suggesting a distinction between Telecom Service Providers (TSPs) operating solely at the network layer and Over-The-Top (OTT) applications functioning exclusively at the application layer. This characterization is fundamentally flawed and misrepresents the technical reality of modern IP communications.

It is crucial to understand that TSPs operate across all seven layers of the Open Systems Interconnection (OSI) model. In the 4G/5G era, TSPs deliver their services through applications that span the entire OSI stack. This comprehensive approach ensures end-to-end service delivery, from physical infrastructure to user-facing applications. Their service delivery is on the application layer of the OSI stack.

Conversely, OTT platforms primarily function at the application layer, relying on the underlying infrastructure and services provided by TSPs. These platforms leverage the robust network architecture and OSI layers, established and maintained by telecom operators to deliver their services.

This mischaracterization overlooks the complex, multi-layered nature of TSP operations and underestimates their crucial role in enabling the digital ecosystem. It is essential to recognize the full role of TSP operations in the telecommunications landscape, particularly as we advance into the 5G era and beyond.

As per our understanding, OTT Communication services are covered under the new Telecom Act as an access service. To address the issues of non-level playing field and ensure adoption of principles of ‘Same Service, Same Rule’, these competing and substitutable services should be included under Access Services authorization under the new framework.”

• Lt. Gen. Dr. S.P. Kochhar, Director General, COAI