India’s telecom sector, ranked as the world’s second largest, is grappling with the challenge of spam calls. Unsolicited commercial communications, robo-calls and fraudulent calls flood communication channels, raising concerns among consumers. There is a critical deficiency in caller identification services. Currently, Indian telecom networks provide only mobile and landline numbers on incoming calls, without revealing the caller’s name. The absence of caller name presentation (CNAP) supplementary services has raised concerns among consumers.

A comparative study conducted by LocalCircles has revealed that over 60 per cent of Indian consumers received three or more spam calls on average every day during the past 12 months. The study also revealed that 30 per cent of the respondents got one to two spam calls on average per day, while 36 per cent reported that they get a minimum of three to five spam calls daily.

Consumers have expressed reluctance to answer calls from unknown numbers. Although smartphone users use third-party applications such as Truecaller and Bharat Caller ID and Anti-spam for caller identification, these solutions rely on crowdsourced data, and there is a lack of a unified solution offered by telecom service providers (TSPs).

Recognising the significance of the issue, the Department of Telecommunications (DoT) had proposed to introduce CNAP as a solution to empower subscribers and mitigate spam calls. However, differing opinions suggested implementing CNAP as a voluntary “opt-in” service rather than a mandatory provision. Concerns have also been raised over privacy infringements, emphasising the need for subscriber consent and comprehensive privacy legislation before CNAP’s widespread adoption. This underscores the need for a balance between consumer protection and technological advancements in India’s telecom sector.

In this context, the Telecom Regulatory Authority of India (TRAI) recently released its recommendations on the introduction of CNAP service in the Indian telecom network. These recommendations are based on stakeholder discussions on TRAI’s consultation paper released in November 2022.

The salient features of these recommendations are…

Need for CNAP service

CNAP is a service that allows recipients of incoming calls to view the identity of the caller. Its fundamental aim is to give individuals the ability to make informed decisions about answering calls by revealing the caller’s identity.

While many stakeholders have supported the integration of CNAP supplementary service in telecom networks, some believe that it is not required. Others have proposed a middle path, suggesting that CNAP service may be introduced in a limited manner. This entails establishing an opt-in, intra-network, consent-based framework for the implementation of CNAP.

However, TRAI has recommended the introduction of CNAP supplementary service in the Indian telecom network. It has recommended all access service providers to provide CNAP service to their telephone subscribers upon request. In addition, originating access service providers should provide the calling name (CNAM) of each telephone subscriber. The name identity information provided by telephone subscribers in the customer application form (CAF) should be used for CNAP.

Name source

Further, TRAI has proposed a mechanism for telephone subscribers whose legal names have changed since the time of submission of the CAF. The recommendation noted that access service providers are advised to establish a process for amending subscriber name information based on explicit requests supported by government-issued verifiable identity documents. This comprehensive approach aligns with TRAI’s vision of enhancing caller identification services while ensuring compliance with regulatory standards and safeguarding subscriber privacy.

Technical model for implementation

DoT, in its background note on the CNAP supplementary service, indicated that the CNAP service should be technology-neutral and independent from internet connectivity. Subsequently, after analysing international experience and available information, TRAI proposed different models for implementing CNAP in its consultation paper in November 2022.

As a large part of the Indian telecom network still relies on circuit switched (CS) core systems, TRAI has recommended that the CNAP service should be implemented in the Indian telecom network using a specific technical model as outlined below:

  • Each access service provider establishes and operates a database containing the subscriber’s name against the telephone number of its subscribers.
  • At the time of receiving a telephone call, based on the telephone number of the calling party, the terminating access service provider queries its local number portability database to determine the originating access service provider of the telephone call.
  • In case the terminating access service provider and the originating access service provider of the telephone call are the same, the terminating access service provider queries its own CNAM database, retrieves the CNAM information and presents the CNAM to the called party.
  • However, in case the originating access service provider of the telephone call is different from the terminating access service provider, the terminating access service provider queries the CNAM database of the originating access service provider, retrieves the CNAM information, and presents the CNAM to the called party.

Maintaining set-up time

The integration of CNAP for all telephone subscribers is expected to impose additional strain on IT infrastructure and network platforms. This increased demand may raise concerns regarding the quality of service, particularly in terms of call latency. Nevertheless, given the current circumstances, a considerable increase in call set-up time is inevitable.

While some stakeholders have asserted that call latency will not increase substantially, a few other stakeholders believe that the implementation of the CNAP service will result in a significant increase in call set-up time, negatively impacting the consumer experience.

Therefore, TRAI has recommended that prior to the nationwide implementation of CNAP supplementary service, a trial and assessment of the CNAP service should be conducted in one licensed service area (LSA) with a subscriber base of each TSP in the LSA. This cautious approach aims to assess the operational feasibility of CNAP while mitigating potential disruptions to service quality and consumer satisfaction.

Device compatibility

Another concern raised pertains to the compatibility of existing mobile handsets and landline telephone sets with the CNAP feature in India. At present, only 4G phones and VoLTE-supported devices introduced after the first quarter of 2021 are equipped with the CNAP functionality as part of their standard feature. In addition, it is uncertain whether this feature is accessible on landline telephone sets currently in use nationwide.

TRAI has recognised the non-homogenous nature of the device ecosystem is, at present, making it difficult to enable the CNAP feature across all telephone devices. Therefore, it has suggested implementing the CNAP feature on devices based on a “best fit” approach. Going forward, the government should issue appropriate instructions for making the CNAP feature available on all devices sold in India. TRAI has recommended that following the acceptance of these recommendations, the government should issue directives to ensure that the CNAP feature becomes a standard offering on all devices sold in India within six months of notification. This strategic action aims to gradually enhance the availability of CNAP across diverse devices, fostering consistency and accessibility for consumers nationwide.

Regulatory provisions

There have been varied responses from industry stakeholders regarding the need for amendments in telecom service licences/authorisations. Accordingly, TRAI has recommended the inclusion of new terms within licensing frameworks to address these concerns. Specifically, TRAI recommended the addition of the term CNAM, referring to the identity of the calling or originating subscriber as per the CAF or any other prescribed identification method by the licensor. In addition, TRAI has suggested incorporating the term CNAP, defined as the presentation of CNAM to the called party by the terminating service provider.

Further, TRAI is of the view that DoT should issue comprehensive guidelines to TSPs for the implementation of CNAP service. It has recommended that licensees adhere to comprehensive guidelines issued by the licensor to ensure the provision of CNAP service in accordance with regulatory standards and evolving industry practices.

The way forward

Given the diverse recommendations and perspectives of industry stakeholders, the implementation of CNAP supplementary service necessitates a comprehensive approach. CNAP service should be studied holistically, with a detailed examination of technical, privacy and cost-benefit aspects, along with an exploration of alternative approaches to achieve the intended objectives within existing regulatory frameworks. This comprehensive assessment is crucial for ensuring the successful integration of CNAP into the telecommunications landscape, enhancing caller identification capabilities while safeguarding consumer interests and regulatory compliance.

Niha