TRAI India regulations - VoIP/IP Telephony

[Vivek Batra]

Considering revenue loss to local PSTN service providers in a region, VoIP to PSTN is still not allowed over WAN. There has been various discussions so far on this subject viz what is allowed and what is not allowed. In absence of clearly defined regulations considering all use cases, there is bit of chaos on the subject. 

In the nutshell as per TRAI, no call routing should happen which is not in the interest of PSTN service provider with respect to toll bypass.

TRAI regulates that IP to PSTN calls are not allowed as long as it bypass the toll otherwise it's allowed.

Allowed Cases:

1. Call between two VoIP phones in same or different geographical locations

If there are offices in New Delhi and Mumbai, calls made from IP phone to IP phone between these two offices are allowed.

There is no geographical restriction to this scenario. If one office is in India and other is in San Jose, still such calls are allowed as long as calls are originated from and terminated to IP terminal.

2. Call from VoIP phone to a PSTN gateway in same geographical location

If there are offices in New Delhi and Mumbai, each site should have local PSTN gateway. Calls originated from New Delhi IP phones must use the PSTN gateway installed within New Delhi office. Same is applicable for calls originated from Mumbai office.

Incoming calls to New Delhi PSTN gateway must be routed to IP phones within office premises. Same is true for incoming calls to Mumbai PSTN gateway.

Needless to say, TEHO scenarios are restricted.

Not Allowed or Restricted:

1. Call that passes through PSTN gateway connects directly by using WAN to a VoIP phone in a different geographical location

If there are offices in New Delhi and Mumbai where each site has local PSTN gateway, calls originated from New Delhi IP phones must use the PSTN gateway installed within New Delhi office. Call must not route over WAN to use the PSTN gateway of remote office say Mumbai PSTN gateway.

Further to this, if PSTN gateway is located outside India, such calls are still not allowed. For example, if there are offices in India and San Jose, call made from India office must not use the PSTN gateway of San Jose as this connection results in revenue loss to service providers.

Other examples

1. Can we a have a conference bridge in India with users dialing from their IP phones or Lync Clients and at the same time some external parties (PSTN) joining that conference?

As regulation doesn't define the case explicitly, this scenario should be conditionally allowed. As long as conference bridge and IP phones are in the same geographical location and someone from PSTN joins the bridge, it's allowed. However, if conference bridge and IP phones joining conference are not in same geographical location, their calls should not get merged with PSTN users joining conference bridge.

2. If there are offices in New Delhi, Pune, Hyderabad and other global locations and conference bridge is in Delhi, can IP phones from Delhi, Pune and Hyderabad dial the conference bridge (on-net internal call) and at the same time have PSTN callers dial in from India/Global locations?

This scenario should not be allowed considering the fact that any IP call over WAN link should not get merged with PSTN. 

3. Considering above case2, can all internal IP phones in India and global can have on-net conference through bridge located in Delhi?

This scenarios should be allowed considering regulations that call from VoIP phone to VoIP phone is allowed. 

Notes:

1. Geographical location

Does geographical location limited to office, campus, city or state? Considering toll bypass perspective of service providers, geographical location should be limited to single site where service provider has given PSTN line.

For example, if we have two offices in the same city, this should be considered as two separate geographical locations.

University kind of installation which is widely spread and have multiple buildings should be considered as campus and come under single geographical location. 

2. While deploying VoIP network within your enterprise, consult and cross verify with your service provider the legal call scenarios to avoid any regulatory issues.

3. Reference

www.trai.gov.in

Cisco documentation

Field discussions

[Muthurani Lavanya Paneerselvam]

Excellent information !  Thanks for sharing.

Regards

Lavanya

Cisco Support Community Moderator

[Terry Cheema]

Good one Vivek - Referencing this link as well it may have some other info:

https://supportforums.cisco.com/discussion/12531631/trai-india-regulations-regarding-voip

-Terry

[Vivek Batra]

Hi Terry,

Thanks for highlighting that link.

Thanks

Vivek

[sabir.bedi1]

Hi Vivek Batra ,

Is this Applicable for customer with dual lines configuration ?

Example 

Line 1 for PSTN  for calling 

Line 2  to for VoIP Calling 

They have already separated their VoIP and PSTN network on IP Phones and are using the separate gateways as well ?

Does in this scenerio the above rules are applicable for PSTN Lines as well ?Since they are in IP Network .

[Mohamed Hussain Siddique]

Hi Vivek

Good explanation , clarified lot of doubts.

 Is there any change to this existing rule ( dont mix Ip with PSTN) ? TEHO is allowed?? i couldn't find any concrete information about any recent changes.

Please do let us know.

Regards

Mohamed

[Vivek Batra]

Hi Mohamed,

Thanks for your comments.

After I wrote this blog, I don't see any further changes in the regulations.

- Vivek

[Vivek Batra]

Hi Sabir,

Irrespective of whether you've same line being used for both PSTN and VoIP or having different lines, thumb rule is in either case VoIP (/WAN) and PSTN call should not get merged in result of normal call, forward, conference etc.

- Vivek

[mubali_123]

Can someone help with the direct link from TRAI website indicating the above points. We have an audit going on in the organization and couldn't show the valid documentation from TRAI explaining the above factors.

[Vivek Batra]

Hi,

I doubt if you get any explicit TRAI reference document on the same otherwise this would not have been a topic of discussion. Although CUCM SRND will cover many of the points listed above under Logical Partitioning chapter.

- Vivek 

[John Clark]

The  question that I have is how MRA fits into this. Are devices connecting via MRA still considered IP endpoints. Are they allowed the calling privileges as on-net endpoints? Or are the considered a PSTN call leg? I have a customer in India that is saying MRA devices are considered a PSTN call leg. The issue becomes for Jabber devices on laptops and smartphones. You can't change the logical partition of the Jabber device when on-net and off-net (not a parameter of the DP roaming settings).

[bibm]

Thanks for the In-depth information with examples Vivek :).

-BIBIN BM

[jsebas200]

Is there any policy for remote agents?

The agent from Mumbai logs in to Bangalore site and access the PSTN. Is it allowed?

[abytalks]

Hello Vivek,

Thanks for the blog, you make good points. However I have a question on jabber, can we use jabber (through vpn) to make PSTN calls as well an internal calls while working from home/remote?.

Same question on the above but through the internet by MRA?

How about Internal video calls in office or remote (vpn)? - I dont see any TRAI talking about video regulations but please let me know if you got any knowledge on this.

I can route the PSTN calls through the local gateway but again the question of Geolocation is tricky for jabber mobility clients since we cant assign a Geolocation filter for jabber clients unlike the hard phones.

What does TRAI has to say about that as per your research?.

Please let me know.

Appreciate your time on this

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Vivek Batra wrote:

Considering revenue loss to local PSTN service providers in a region, VoIP to PSTN is still not allowed over WAN. There has been various discussions so far on this subject viz what is allowed and what is not allowed. In absence of clearly defined regulations considering all use cases, there is bit of chaos on the subject. 

In the nutshell as per TRAI, no call routing should happen which is not in the interest of PSTN service provider with respect to toll bypass.

TRAI regulates that IP to PSTN calls are not allowed as long as it bypass the toll otherwise it's allowed.

Allowed Cases:

1. Call between two VoIP phones in same or different geographical locations

If there are offices in New Delhi and Mumbai, calls made from IP phone to IP phone between these two offices are allowed.

There is no geographical restriction to this scenario. If one office is in India and other is in San Jose, still such calls are allowed as long as calls are originated from and terminated to IP terminal.

2. Call from VoIP phone to a PSTN gateway in same geographical location

If there are offices in New Delhi and Mumbai, each site should have local PSTN gateway. Calls originated from New Delhi IP phones must use the PSTN gateway installed within New Delhi office. Same is applicable for calls originated from Mumbai office.

Incoming calls to New Delhi PSTN gateway must be routed to IP phones within office premises. Same is true for incoming calls to Mumbai PSTN gateway.

Needless to say, TEHO scenarios are restricted.

Not Allowed or Restricted:

1. Call that passes through PSTN gateway connects directly by using WAN to a VoIP phone in a different geographical location

If there are offices in New Delhi and Mumbai where each site has local PSTN gateway, calls originated from New Delhi IP phones must use the PSTN gateway installed within New Delhi office. Call must not route over WAN to use the PSTN gateway of remote office say Mumbai PSTN gateway.

Further to this, if PSTN gateway is located outside India, such calls are still not allowed. For example, if there are offices in India and San Jose, call made from India office must not use the PSTN gateway of San Jose as this connection results in revenue loss to service providers.

Other examples

1. Can we a have a conference bridge in India with users dialing from their IP phones or Lync Clients and at the same time some external parties (PSTN) joining that conference?

As regulation doesn't define the case explicitly, this scenario should be conditionally allowed. As long as conference bridge and IP phones are in the same geographical location and someone from PSTN joins the bridge, it's allowed. However, if conference bridge and IP phones joining conference are not in same geographical location, their calls should not get merged with PSTN users joining conference bridge.

2. If there are offices in New Delhi, Pune, Hyderabad and other global locations and conference bridge is in Delhi, can IP phones from Delhi, Pune and Hyderabad dial the conference bridge (on-net internal call) and at the same time have PSTN callers dial in from India/Global locations?

This scenario should not be allowed considering the fact that any IP call over WAN link should not get merged with PSTN. 

3. Considering above case2, can all internal IP phones in India and global can have on-net conference through bridge located in Delhi?

This scenarios should be allowed considering regulations that call from VoIP phone to VoIP phone is allowed. 

Notes:

1. Geographical location

Does geographical location limited to office, campus, city or state? Considering toll bypass perspective of service providers, geographical location should be limited to single site where service provider has given PSTN line.

For example, if we have two offices in the same city, this should be considered as two separate geographical locations.

University kind of installation which is widely spread and have multiple buildings should be considered as campus and come under single geographical location. 

2. While deploying VoIP network within your enterprise, consult and cross verify with your service provider the legal call scenarios to avoid any regulatory issues.

3. Reference

www.trai.gov.in

Cisco documentation

Field discussions

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