The Telecom Regulatory Authority of India (TRAI) recently released a consultation paper on the introduction of calling name presentation (CNAP) in In­dian telecommunication networks. CNAP is a service that allows the recipient of in­co­ming calls to see the identity of the call­er. The main objective of CNAP is to provide individuals with the ability to make informed decisions about answering calls by revealing the caller’s identity.

In India, incoming calls only display mo­bile/landline numbers as calling line id­en­tification (CLI). For smartphone users, there are some third-party applications such as Truecaller and Bharat Caller ID &Anti Spam that identify the calling party and mark spam calls. However, they rely on crowdsourced data, and there is a lack of a unified solution offered by telecom service providers.

The mandate of implementing CNAP in India has received mixed reactions from industry stakeholders. A look at the global developments and key arguments in the debate around CNAP in the Indian context…

Global developments

In 1996, the International Telecommuni­ca­tion Union defined calling name identification presentation as “a supplementary service that provides the name information associated with the calling party to the called party”. Later, in 2012, the European Telecommunication Standards Institute released a technical specification, providing a similar definition for CNAP. Further, in 2021, 3GPP2 issued a technical specification that introduced, among other things, the specifications of two supple­me­n­tary services – originating identification presentation and enhanced calling name.

Several countries have implemented th­is service. In the US, the caller’s name is not sent during a call. Instead, the terminating service provider provides the caller ID information to its customer by looking up the database maintained by the originating service provider or a trusted third party. In Canada, the calling party name information is sent over the telecommunication network from the originating service provider to the terminating service provider. Meanwhile, in Turkey, service pro­viders are allowed to use the sender’s name, commercial name, a public institution or a non-governmental organisation’s name, trademarks and patents as CLI, provided the respective subscribers possess official documents to prove their legitimate right to use these names. In 2019, the Telecommunications and Digital Govern-ment Regulatory Authority of the UAE announced requirements for implementing the CNAP feature for all new and exi­sting mobile phones in the country.

TRAI’s proposal

In its consultation paper, TRAI has expre­s­sed its concern that without the CNAP facility, the CLI service alone does not provide enough information for consumers to trust that a call is legitimate. As a result, even genuine calls go unanswered, resulting in missed opportunities for both the caller and the receiver. According to the regulator, consumers are actively seeking the ability to view the calling party’s name on their phones as a means to combat the prevalence of spam calls.

TRAI has proposed four possible models through which the CNAP feature can be implemented:

  • In the first model, TRAI proposes that telcos would manage a CNAP database of their respective subscribers. The data would be extracted from the database when a telco’s user makes a call to a user on another network, and presen­ted to the receiving telco’s user. How­ever, implementing this model would require telcos to upgrade their current network nodes.
  • The second model is similar to the first one, except that the operator through which the call is made would need to grant the receiving operator access to its CNAP database.
  • The third method involves a third party operating a centralised database. In this model, the receiving telco would be responsible for accessing the centralised database to retrieve and provide the calling party’s data.
  • The fourth model requires each operator to retain a copy of a synchronised ce­n­tral database operated by a third party.

TRAI is of the view that in the first and fourth models, the increase in call set-up time would be lower than in the other models, resulting in less hindrance to the latency of the call flow mechanism.

However, many entities opposing the feature believe that none of the four im­plementation models proposed by TRAI can be executed in India. According to Vo­da­fone Idea Limited (Vi), all the models wo­uld increase the switching time/process­or load, latency and delay in call set-up ti­me, and incur huge costs for telcos. The Ce­ll­ular Operators Associa­tion of India (COAI) shares the opinion that all the models involve substantial latency and high costs for implementation as well as potential risks to subscriber information with th­i­rd parties in some models. COAI believes that implementing CNAP should be optional rather than mandatory for telcos.

Industry perspective

Industry associations and organisations have pointed out a number of issues with the implementation of CNAP services in Indian telecommunication networks. Some of the major ones are:

Data privacy

The foremost concern expressed by industry stakeholders is the threat to subscriber data privacy. Providing CNAP would require using consumer data, which would be under the control of handset manufacturers and operating system (OS) providers. According to COAI, this could result in the breach of subscriber data privacy as mobile device manufacturers and OS providers would have access to subscriber information from the entire country. Further, consumers may not be willing to share their name for various reasons such as fraud, social media stalking and risk of abuse. It will be important to take the calling party’s consent before sharing their na­me with the called party. However, Bharti Airtel suggests that if a consent mechani­sm or an opt-in approach is adopted, the chances of CNAP becoming ineffective will become high as violators may choose to opt out of it, defeating the purpose of the CNAP service. COAI argues that any misalignment between pri­vacy requirements and the CNAP mandate will make it difficult for operato­rs to provide customers with a consistent user experience. It may also cause legal uncertainty for telcos.

Compatibility with handsets

Another challenge has been highlighted by stakeholders at the device level. Handsets such as 2G feature phones do not support the CNAP functionalities while most new smartphones are capable of supporting the feature, as it is a 3GPP feature. However, the feature is kept off by most original eq­uip­ment manufacturers (OEMs) as it is not a mandatory requirement in most jurisdictions. According to Reliance Jio, there can be a large segment of smartphones that will require intervention at the OEM le­vel, in the form of testing and firmware-over-the-air updates or otherwise, to en­able the feature. COAI has suggested that this could cause confusion regarding the applicability of CNAP and make it difficult for telcos to implement it.

Technical difficulties

CNAP is a LTE feature and there are no standards for its implementation over 2G/3G networks. Hence, there is no readily available solution for it. The development and deployment of a solution would require extensive testing before being as­sured of its proper working. Furthermore, Vi has expressed that CNAP over telecommunication networks would work only on IP-interconnect and not on time division multiplexing (TDM) interconnects. Cur­r­ently, a large proportion of traffic between operators is served through TDM interconnect. Jio has highlighted another technical issue, which is the increasing load on signalling. This would lead to a longer call set-up time, which will not only increase network load but will impact latency as well. CNAP implementation will impose a huge expenditure on telcos’ network, IT systems and processes. It would impact the circle-level and node-level architecture.

Consumers’ standpoint

Several consumer advocacy groups such as Consumer Guild and VOICE have submitted their feedback in favour of mandatory activation of CNAP in India. According to VOICE, a centralised CNAP is the most viable option and it should be managed by a constitutional en­tity amenable to right to information and other regulations available under consumer protection. However, the Consu­mer Unity & Trust Society has op­posed the mandate, citing consumer data privacy risks, possibility of delays in call set-up ti­mes and deterioration in the quality of services for consumers.

The bottom line

Implementing CNAP in India would be a favourable move for consumers due to the widespread issue of unsolicited commercial communications. However, the solution sh­ould add value for all stakeholders, inclu­ding enterprises, handset manufacturers and telecom operators. Therefore, it should on­ly be implemented after a consensus is ac­hi­eved. Further, the CNAP feature poses pri­va­cy risks if not correctly implemented, ma­king it necessary to have an effective data protection regime in pl­ace prior to its roll-out. A de­tail­ed cost-be­nefit analysis or regulatory impact assessment, as advocated by various industry bo­dies, should be conducted before the im­plementation of CNAP in India.

Sarah Khan