TRAI push or industry pressure: Why is DD Free Dish facing calls for reforms?

Concerns are mounting within India’s broadcast and advertising industries over the lack of transparency and regulatory oversight surrounding Doordarshan’s free-to-air direct-to-home platform, DD Free Dish.

While the service has seen massive growth in reach and popularity since its launch in 2004, stakeholders across the ecosystem, private broadcasters, advertisers, and industry bodies, argue that its unchecked expansion now distorts market competition, undermines regulatory intent, and raises urgent questions of fairness and accountability.

At the heart of the debate are three key issues - the absence of transparent subscriber data, the transmission of unencrypted signals despite legal mandates, and the commercial consequences of a government-backed platform competing with private operators without the same compliance burden.

A platform without accountability
Unlike private DTH and cable operators, which are legally bound to use Conditional Access Systems (CAS) and Subscriber Management Systems (SMS) audited regularly to ensure accuracy, DD Free Dish functions as a non-addressable platform.

Its set-top boxes, many distributed without Doordarshan branding or traceability, make it impossible to verify how many are actually seeded, active, or in use, say industry experts.

“This lack of addressability means viewership numbers are at best speculative. Industry reports cite a wide range anywhere between 30 million and 65 million households but none of these figures can be independently verified. Even agencies like TRAI and Deloitte rely largely on extrapolated estimates rather than hard data,” said a broadcast expert.

Regional inclusion
Manoj Chhangani, Secretary of the All India Digital Cable Federation (AIDCF), summarised the concern bluntly, saying, the reach of DD Free Dish is speculative.

“The reach of DD Free Dish is at best speculative. Since the platform is non-addressable, there is no mechanism to record actual subscriber numbers. Unlike private cable and DTH platforms, which are mandated to deploy CAS and SMS that are audited for accuracy, DD Free Dish has no such systems.

“Different industry reports place its reach anywhere between 30–50 million households, but these figures cannot be independently verified. This lack of addressability and transparent measurement has been repeatedly flagged by stakeholders and acknowledged by TRAI itself. Without a reliable baseline, both policymakers and advertisers are making decisions on data that is essentially unverifiable,” he said.

The encryption gap
A second, more structural issue is encryption. DD Free Dish continues to transmit signals in unencrypted MPEG-2 format, even though a 2014 government mandate prohibited analog transmission without encryption.

“Private DTH operators like Tata Play and Airtel are required to comply strictly with this rule, investing heavily in digitization and encryption technologies,” said another expert.

Highlighting the unfairness, Chhangani said that by transmitting signals in an unencrypted, free-to-air manner, DD Free Dish undermines the level playing field.

“Private operators have invested heavily in digitization, CAS, SMS, set-top boxes, and consumer grievance mechanisms, as mandated by the law. DD Free Dish bypasses all these requirements. This not only encourages piracy and unauthorized redistribution but also pulls away subscribers from licensed platforms that are compelled to operate under higher cost structures,” he said.

The Telecom Regulatory Authority of India (TRAI) has itself acknowledged the problem. In its July 2024 recommendations, it urged Prasar Bharati — which operates DD Free Dish — to move towards an addressable, encrypted framework.

TRAI had recommended converting DD Free Dish into an addressable system, encrypting signals of private TV channels at the Free Dish headend before uplinking, prohibiting the use of non-addressable set-top boxes, and undertaking a phased deployment of Conditional Access System (CAS) and Subscriber Management System (SMS).

Rajiv Khattar, a broadcast expert, emphasised why this transition is urgent.

“The right way forward is that MIB should accept TRAI recommendations on encrypting DD Free Dish—if not fully, then at least for MPEG-4 channels. This way, the current viewers will continue to get around 100 channels and DD will get carriage for those. Slowly, the encrypted boxes will penetrate and then numbers will be available with authenticity. Now with TVs coming with built-in tuners, if encryption is not adopted it will further hit the pay TV business,” he said.

Responding to such concerns, Gaurav Dwivedi, CEO, Prasar Bharati, maintained that the platform’s structure reflects a conscious policy choice.

“The auction process is conducted strictly as per pre-defined rules, and access to information is limited to stakeholders. As far as DD Free Dish being unencrypted is concerned, that was a deliberate decision of the Government of India,” he said.

“Public service broadcasting cannot be placed behind an access barrier. Basic services must remain free to citizens, while those who seek premium services have ample addressable and encrypted options available in the market. There is absolutely no rethink on that.”

Impact on private players
The consequences of DD Free Dish’s unencrypted, unverifiable operations are stark. Private DTH and cable platforms who have spent years building digitized, addressable networks — face both commercial losses and regulatory frustration.

First, unencrypted signals make piracy rampant. Smaller cable operators often intercept Free Dish feeds and retransmit them without authorization, depriving legitimate operators of subscribers. Second, DD Free Dish’s lack of compliance means it can offer free access to a wide range of content without incurring the same costs as private players, thereby undercutting them in both subscription and advertising markets.

As Chhangani put it, “In its current form, DD Free Dish not only distorts the broadcasting and advertising ecosystem but also represents a situation where the government, through Prasar Bharati, is competing commercially with the very private operators it regulates. Bringing DD Free Dish into the addressable, auditable framework is essential for transparency, accountability, and the long-term sustainability of India’s broadcasting sector.”

Distortions in advertising spend
If broadcasters feel the pinch from subscriber loss, advertisers face an equally critical dilemma. Without reliable subscriber data, brands making ad spend decisions are essentially shooting in the dark.

An advertising expert explained the distortion, saying, “The absence of transparent subscriber data means advertisers often rely on inflated or unverifiable reach claims, leading to distortion in the allocation of advertising budgets. Advertisers are often led to believe that the platform enjoys far higher penetration than it actually does. As a result, spends are diverted from regulated platforms with independently verifiable viewership data to DD Free Dish, where neither reach nor audience engagement can be accurately tracked. This creates market inefficiency and unfairly disadvantages private players who invest in measurement and compliance.”

Another advertising expert added that the only solution is to bring DD Free Dish under the same regulatory framework as private operators, echoing TRAI’s recommendations to ensure accurate subscriber data through addressable set-top boxes and allow advertisers to rely on credible viewership data for media planning.

TRAI has consistently pushed for reforms. In addition to encryption and CAS/SMS deployment, its 2024 amendments recommended interoperable set-top boxes—a move aimed at empowering consumers by eliminating the need to switch devices when changing service providers.

TRAI had said, “Prasar Bharati should adopt interoperable STBs for DD Free Dish to act as a catalyst for transitioning the entire ecosystem from operator-based STBs to interoperable STBs to empower consumers’ choice. This will eliminate the need for changing STBs every time the service provider is changed.”

It also noted that during stakeholder consultations, multiple related issues surfaced—piracy, market fairness, consumer protection—that require further exploration. TRAI promised a comprehensive consultation paper in the near future.

Yet, despite regulatory intent, implementation has lagged. The Cable Federation even approached TDSAT, accusing DD Free Dish of flouting TRAI regulations requiring encrypted transmission of private channels. Their appeal highlighted the frustration among private players who remain bound by costly compliance while Prasar Bharati operates outside the same boundaries.

Launched in 2004 with just 20 channels, DD Free Dish has grown rapidly to host more than 200 channels today. Its popularity, particularly in rural and lower-income households, stems from its promise of free access—a feature that undeniably supports public service broadcasting goals.

However, this success story carries a paradox: while DD Free Dish fulfills a social mission of ensuring affordable access to information and entertainment, its unregulated commercial operations erode the very market structure that sustains India’s broader broadcasting ecosystem.

By allowing unencrypted, unverifiable operations to continue, the government risks undermining both private sector investment and advertising efficiency. At a time when the media industry faces disruptions from OTT platforms, shrinking subscription bases, and evolving consumer behavior, such distortions only deepen instability.

The way forward
The debate over DD Free Dish is no longer about whether reform is needed, it is about how soon and how decisively it will be implemented.

Stakeholders appear aligned on several key points. They stress that without encryption, piracy will persist, subscriber data will remain unverifiable, and advertising distortions will continue, making a phased migration to encrypted, addressable systems essential.

A level playing field is also seen as critical, with calls for DD Free Dish to be subjected to the same tariff, interconnection, and QoS obligations as private operators. Transparency in measurement is another concern, with industry voices insisting that only audited CAS and SMS data can give advertisers and policymakers reliable figures. On the consumer side, interoperable set-top boxes, as recommended by TRAI, are viewed as both empowering for users and aligned with India’s broader digitization agenda.

Finally, there is consensus that the Ministry of Information and Broadcasting must act decisively on TRAI’s recommendations and ensure Prasar Bharati adopts reforms in a time-bound manner.

DD Free Dish has undeniably expanded access to television content across India, fulfilling Doordarshan’s mandate of public service broadcasting. But in its current form non-addressable, unencrypted, and unaccountable, it distorts markets, encourages piracy, and undermines the very regulatory framework designed to ensure fairness.

As Chhangani warned, “Bringing DD Free Dish into the addressable, auditable framework is essential for transparency, accountability, and the long-term sustainability of India’s broadcasting sector.”

With advertising spend, private investments, and consumer trust at stake, the urgency of reform can no longer be ignored. Unless encryption, transparency, and parity are enforced, DD Free Dish risks becoming not just a free-to-air service, but a free pass to market distortion.