Telecom Regulatory Authority

Telecom R of India

Consultation Paper
on
Review of extant provision for sending the printed bills to
consumers of landline and Post paid Mobile subscribers

New Delhi, 15th November, 2018

Mahanagar Door Sanchar Bhawan, Jawahar Lal Nehru Marg,

New Delhi – 110002

Website: www.trai.gov.in
Stakeholders are requested to furnish their written comments by
10th December 2018 and counter-comments by 24th December 2018
to Shri Kaushal Kishore, Advisor (F&EA-I), TRAI. Comments and
counter-comments would be posted on TRAI’s website
www.trai.gov.in. The comments and counter-comments may also
be sent by e-mail to [email protected]. For any
clarification/information, Advisor (F&EA-I) may be contacted at
Tel. /Fax No. : +91-11-23234367.
 Contents

Chapter No. Item Page No.

1. Introduction 1-5

2. Background for consultation 6-12

3. Demographic profile in terms of 13-17

education, e-literacy, Age and
affordability of smart phone
4. E-billing in Utilities billing system 18

5. International Practices 19-21

6. Issues for consultation 22
7. Annexures 23-35
 Chapter 1

Introduction
Current consultation exercise is about the review of the prevailing provisions
(introduced through 46th Amendment in 2008 to Telecommunication Tariff Order,
1999) for providing printed bill to subscribers of post paid wire line and post paid
mobile services. In this context current chapter lists the extant regulatory provisions
that have some bearing on this consultative exercise with a view to set the context
and provide a ready-reckoner to the stakeholders to facilitate an informed discussion.

Provisions in the Telecom Regulatory Authority of India (TRAI) Act 1997

1.1 The preamble of the Telecom Regulatory Authority of India (TRAI) Act, 1997
reads as under:
“An Act to provide for the establishment of the [Telecom Regulatory Authority of
India and the Telecom Disputes Settlement and Appellate Tribunal to regulate the
telecommunication services, adjudicate disputes, dispose of appeals and to protect
the interests of service providers and consumers of the telecom sector, to promote
and ensure orderly growth of the telecom sector] and for matters connected
therewith or incidental thereto.”1

1.2 The Telecom Regulatory Authority of India (TRAI) has, inter-alia, also the
mandate to regulate tariff for telecommunication services in India. Section 11(2) of
the Chapter III of the Telecom Regulatory Authority of India Act, 1997 lays down
that:
“(2) Notwithstanding anything contained in the Indian Telegraph Act, 1885 (13 of
1885), the Authority may, from time to time, by order, notify in the Official Gazette
the rates at which the telecommunication services within India and outside India
shall be provided under this Act including the rates at which messages shall be
transmitted to any country outside India:
Provided that the Authority may notify different rates for different persons or class of
persons for similar telecommunication services and where different rates are fixed as
aforesaid the Authority shall record the reason thereof.”2

Provisions in Indian Telegraph Rules, 19513:

1.3 The telephone bill issued by Telecom service provider to subscribers gives
complete picture of the service actually provided by service provider which, inter-alia,
includes details of the service, rates and related terms and conditions, actual usage
of service during the period, amount payable by the subscriber and due date of

1
https://www.trai.gov.in/sites/default/files/The_TRAI_Act_1997.pdf
2
ibid
3
Indian Telegraph Rules, 1951
1
payment. Under the provisions of the Indian Telegraph Rules, 1951, the charges for
calls message rate and measured rate system shall become payable on presentation
of a bill. It also stipulates that, any notice, bill or demand from the Telegraph
authority for any fee or charges due from a subscriber may be served by delivery to
the subscriber, or by sending it by post to the address of the subscriber or by leaving
it at the premises or upon which the apparatus is installed.
Rule 439 of the Indian Telegraph Rules, 1951 reads as under:-
“439. Charges when payable: Charges for calls in message rate or
measured rate system shall become payable on presentation of a bill
thereof. The periods for which bill shall be prepared and the dates by
which they shall be payable shall be fixed by the Telegraph Authority.”

Rule 442 of the Indian Telegraph Rules, 1951 reads as under:-

“442. Service of notice and bills: Any notice, bill or demand from the
Telegraph Authority for any fee or charges due from a subscriber may be
served by delivery to the subscriber, or by sending it by post to the
address of the subscriber or by leaving it at the premises in or upon which
the apparatus is installed.”

Provision in Telecommunication Tariff Order (TTO), 19994:

1.4 In exercise of the power assigned to it through TRAI Act, Telecommunication
Tariff Order (TTO), 1999 was notified for the first time on 9th March, 1999.
Amendments to the TTO, 1999 have been made from time to time to reflect the
evolving telecommunication landscape. As a result, the TTO itself has since been
amended sixty four times to factor in the changes and developments in the sector.

1.5 In the last 19 years since the TTO was first notified, the telecommunication
sector in India has witnessed a number of changes in the telecom ecosystem in
respect of technologies deployed, types of telecom services, market composition,
competition, user profile and usage pattern. The main highlights of the TTO are:
a) Limits on Tariff: Provision of ceiling and floor on certain telecommunication
services.
b) Reporting Requirement: TSPs have to report to TRAI any new tariff and
the subsequent changes.
c) Transparency and Consumer Protection: Tariff charged along with the
terms and conditions attached to it by the TSPs should be published in a
manner as prescribed by TRAI from time to time.

4
https://trai.gov.in/sites/default/files/Main_Regulations_09_Mar_1999.pdf
2
Provision in Telecom Consumer Protection Regulation (TCPR), 20125:
1.6 In addition to the TTO, various regulations, directions and advisories have been
issued by TRAI to meet the regulatory requirements. For example, the TCPR, 2012
defines the features of various mobile prepaid products and also addresses
transparency issues.

Provisions in the License Agreement6:

1.7 Besides the above mentioned provisions in the TRAI Act, 1997, the TTO, 1999
and the TCPR, 2012, CMTS license agreement (Condition 7 in Part I of Schedule II)
and the Unified Access Service license agreement (Clause 30.4) also, inter-alia,
stipulate that it shall be the responsibility of the licensee to issue or cause to be
issued bills to its subscribers for use of the service. As per these licensing conditions,
the billing system of the licensee shall be able to generate the billing information, in
adequate details, to ensure satisfaction to the customer about the genuineness of
the bill. The license agreements for these services also mandates that the directions
of TRAI, from time to time, in this regard shall apply.

Previous Consultative exercise on the subject:

1.8 In this backdrop, through a consultation process in 20087 Authority invited
comments of stakeholders on the proposal for amending the Telecommunication
Tariff Order to incorporate an explicit provision for providing bill in hard copy free of
cost to all post paid subscribers. Rationale for this was complaints of mobile service
provider‟s insistence on providing bills through SMS or email only to a post-paid tariff
plan and the hard copy of the bill being available to the subscribers only on payment
of a fixed amount as determined by the service provider. Stakeholders including
Service Providers, Consumer Organizations and Associations of Service Providers
overwhelmingly welcomed this proposal and informed that they were already giving
hard copy of the bill free of cost to their post-paid customers. Various suggestions
were received which included clarity as regards the provision of printed copies of the
itemized bills for local calls and Short Message Service (SMS) to consumers,
provisions of itemized bills for local calls and SMS to be chargeable. It was also
suggested at that time, considering the convenience of electronic bills to a large
section of subscribers, hard copy of bills should not be mandated and choice of
receiving bills, hard copy or soft copy, should be left to subscribers.

During the consultation, some suggestions against the proposal were also received
such as the one that even after getting bills in electronic form, if a customer insists
for a hard copy of the bill, then it should be at a cost, and that considering the
convenience of electronic bills to a large section of subscribers, hard copy of bills
should not be mandated and choice of receiving bills, hard copy or soft copy, should
be left to the subscribers. Consumers and Consumer Organizations favored the

5
https://trai.gov.in/sites/default/files/Consumer_Protection_Regulations%202012.pdf
6
http://www.dot.gov.in/sites/default/files/UAS%20license-agreement-19-12-2007.pdf?download=1
7
https://trai.gov.in/sites/default/files/caper31dec07.pdf
3
proposal of the Authority by stating that such a move would go a long way in
educating and informing laymen consumers to know the details of their bills. It was
opined that the purpose of issuing or obtaining the telephone bills through hard
copy, inter-alia, are to -
a) understand and satisfy oneself about the genuineness of the bill;
b) facilitate making of payment;
c) verify the charges incurred by the consumer;
d) monitor usage or expenditure by consumer.

1.9 In order to make the billing more transparent and consumer friendly TRAI has
been undertaking studies on the presentation of the bills to the consumers and
issuing Directions8 on-
 specifying various guidelines as to how the bill should be presented to the
consumers.
 provision of usage details even to the pre-paid mobile users.
 Specifying a number of information, which are useful to the consumers, to be
captured in the bill.

It was felt that all the crucial details cannot be easily, conveniently and
comprehensively captured in short message service (SMS) and bill sent through SMS
would not give sufficient clarity to subscribers. Most of the consumers, such as those
from low income category may not have a compatible phone, access to computer
and internet to obtain the telephone bill through e-mail. Access to e-mail is normally
not available to the persons who are in the low-income category. It was therefore,
felt that it would not be consumer friendly to permit service providers to levy extra
charges for providing hard copy of the bill. It was also noted that the service
providers of other sectors such as Electricity Corporations, Water Utilities services,
and Financial Institutions, etc., are not charging any amount for providing the hard
copy of the bill.

TTO 46th Amendment, 20089:

1.10 The Authority after examining the issue in the light of the Indian Telegraph
Rules, 1951, license agreements for Cellular Mobile Telecom Service (CMTS), Unified
Access Service, National Long Distance (NLD) and International Long Distance (ILD)
services relating to billing and customer service and view of stakeholders issued the
TTO 46th Amendment 2008 mandating the service providers to provide hard copy of
the bill to its post-paid subscribers of (i) Basic Service (other than ISDN) and (ii)
Cellular Mobile Telecom Service free of cost. However, if any customer opts for
receipt of the bill through e-mail, instead of hard copy, the service providers can
supply the same after obtaining explicit consent from the consumers. In all other
cases, the service provider must ensure that the bills are generated and delivered to
the consumers in printed form free of cost. The TTO (46th Amendment) 2008, along

8
https://trai.gov.in/sites/default/files/Direction-02-may2005.pdf
9
https://trai.gov.in/sites/default/files/46Forty_Sixth_Amendment_24_Jan_2008.pdf
4
with its explanatory memorandum is enclosed as Annexure-A to this consultation
paper for ready reference of the stakeholders.

1.11 Next chapter discusses the recent developments in light of which the current
consultative exercise has been initiated.

5
 Chapter-2
Background for Consultation
After listing the extant regulatory provisions that prevail today on the subject under
discussion in brief, in chapter 1, this chapter gives the background including, inter-
alia, the subscriber and service providers perspectives in which the instant
consultative exercise has been initiated.

Representations from Telecom Industry and their Associations:

2.1 The Authority has been intermittently receiving representations, from Telecom
service providers and their associations requesting a review of the provision of the
TTO (46th Amendment, 2008) which mandates provision of hard copy of the bill or
the printed copy of the bill to post paid subscribers and removal of the mandate of
providing hard copy of the bill with Mobile Bill (M-Bill) or E-Bill as the default option.
Environmental concerns relating to cutting of trees for papers used in printing of bills
and changing mobile usage scenario in the context of massive surge in data usage
on smart phone were put forth to bolster their demand. as the main rationale to this
demand. The matter has been discussed with TSPs and their associations many
times ever since the above mentioned representations were received. Various
perspectives proposed by the TSPs and the associations as possible alternatives to
the printed bills, size and contents of the electronic bill, profile of the customers
(age, income group, disability, if any) as well as users having feature phones not
compatible with electronic bill delivery have been examined by the Authority.
However, the options that emerged from these deliberations, so far, did not provide
any conclusive ground for amending the TTO (46th Amendment). Main arguments in
addition to the environmental concerns, that have been put forth in support of
default provision of electronic bills to post paid subscribers are as given below:

(I) Advancement in Technology: Initial discussions on M-bill or e-bill issue were

focused on the way electronic bills would be sent and set of information to be
contained in them, as many of the subscribers would not have access to Internet.
With advent of 4G/4G VOLTE technology and other advanced technologies in the
mobile telephony, usage of data has dramatically increased since last few years.
Delivery of electronic bills critically depends on Internet, through which email,
websites and other platforms can be accessed for receiving bills. The spread and
easy access of Internet could provide access to full size bills to majority of
subscribers. It is a fact that there has been a sharp increase in internet use and
consumption of data in past few years.

6
Source: TRAI Data

(II) Cost of Data service and Smart Phones: Trends in price of data service as
well as smart handsets during last two years show that more and more people have
gained affordability to purchase a smart phone and consume more data on a high
speed platform. This scenario indicates a gradual shift towards a paperless billing
system to be adopted by telecom sector in tune with many other sectors of
economy.

(III) The time gap since the issue of the 46th Amendment:
The 46th Amendment to TTO, 1999 was notified in 2008. TSPs have argued that
mere fact of the passage of a decade since issue of the extant provisions merits a
review of its relevance.

Representations from Hon’ble MPs/ MLAs/MLCs from Maharashtra:

2.2 Authority has recently received twenty four similar representations from Hon‟ble
MPs/MLAs/MLCs, some prominent citizens and TSPs, who have argued that doing
away with mandatory provision of hard copy of bill, would be in tune with „Digital
India Mission‟, apart from addressing a serious environmental concern. Sample copy
of such representations (more or less identical) is enclosed at Annexure-B. All these
representations are from Maharashtra.

Joint Committee Report:

2.3 Apart from the recent developments mentioned in preceding para 2.2 in the
beginning of 2017, it may be mentioned that TRAI constituted a joint Committee on
27.03.2017 of senior officers of TRAI and service providers and their Associations to
identify infructuous/redundant regulations relating to License, QOS and Tariffs which
7
could be purged. One of the proposals discussed by the Committee was provisions of
TTO (46th Amendment). The joint Committee, in their final recommendations after
due deliberation, recommended as under:
“Schedule II- Cellular Mobile Telecom Service (CMTS)- Item (7A)- Forty Sixth
Amendment- Tariff for provision of hard copy of the bill or printed copy of the bill to
the customer– Nil.”
To be re-worded, so as to introduce option “opt-in” by the subscriber for hard copy
of the bill, if so required.
The above recommendation seeks to introduce a change in the present provision in a
manner that the default option for receiving a bill would be the electronic bill and
hard copy of the bill has to be provided to those subscribers who would opt-in for
hard bill. This recommendation addresses the demand made by the industry and
their associations as well as some other stakeholders as mentioned in above
paragraphs. However, this committee didn‟t have any representation of consumers
and to this extent the recommendations of the committee does not reflect the
consumer views on the subject. Consumers form the most important segment of
stakeholders on this issue. It has therefore, been decided by the Authority to hold a
public consultation to have views of all the stakeholders, in the matter so that a
holistic approach could be adopted to address this important issue affecting Telecom
consumer‟s rights.

Important issues concerning subscribers

2.4 As per extant regulatory regime of telecom tariffs in India, the subscribers have
the right to know and verify the charges levied by the service providers without any
exception. During the Consultation process in 2008, the Authority stated that a
classification of low end subscribers based on monetary value suggested by the
Industry Association is likely to be termed as arbitrary as usage and bill values are
relative in nature. It also said that „low-end‟ customers are the ones who cannot
generally afford to have access to computer / smart phone/ internet and, therefore,
it is this category of customers who needs protection. An electronic bill served on a
feature phone may not be capable of displaying all the vital information required to
be given as per norms.

2.5 Apart from the observations referred in preceding paragraph, it would be prudent
to examine the concerns of various stakeholders on the matter before the industry
demand for change in the extant position is considered. Some major issues of
consumer concern in this regard could be-
a) The onus of downloading and printing of bill and as such bearing the cost of
the same, which was hitherto a responsibility of the TSP would shift to the
subscriber in e-bill/m-bill environment.
b) Industry has been arguing about High cost of providing hard copy to a large
number of postpaid subscribers. While removing of default paper bill option
suits TSPs but at the same time, making e-bill/M-bill as a default option would
amount to denial of information to this section of subscribers.

8
 c) Industry has also been proposing the new concept of M-billing introduced for
those customers who are not opting for e-bill because they do not have an
email account. In M-Bills, the basic details of the bill would be provided
through the SMS with a link in the SMS to reach to the complete bill. It has
been argued by TSPs that the customers of the feature phones can print the
bill using the link free of cost from multiple channels. But such M-bills access
and printing through designated sources would be with cost impact and also
the inconvenience.
d) The issue of inconvenience and costs related to feature phone holders, and
the senior citizens, disadvantaged groups and rural population have not been
covered in any of the representations of the industry. Alternative solutions
such as compensatory incentive for the shift of burden of
downloading/printing from TSPs to subscribers and waiver of Senior citizens
from the default options of M-bill who would continue to receive hard copy of
bill, are also missing in the representations received in TRAI.
e) The requirement of provision of hard copy mandated through TTO is only in
respect of the basic/summary bill and itemized bill in respect of long distance
calls. The issue of itemized bill in respect of local calls, SMS and data usage is
not mandatory and is under forbearance. Such basic/summary bill continues
to be the right of consumers for reasons explained in the Explanatory
Memorandum of the TTO (46th Amendment).
f) The fact that despite the efforts of telecom service providers, a substantial
portion of postpaid subscribers have not opted for e-billing shows that there is
large number of subscribers who still insists on hard copy of the bill. The
COAI‟s representations to the Authority do not elaborate on the kind of efforts
taken by TSPs in this regard. There may be some obvious reasons why
substantial segment of subscribers are not opting for e-bill, like limited access
to email facility, familiarity with e-bill system, age profile and e-literacy of the
subscribers of this segment. Considering the fact that bills only concern less
than 5% of total mobile subscriber base (only postpaid subscribers) apart
from majority of landline subscriber, a concerted inducement campaign and
personal reach could be useful in making more people opt out from hard copy
of bill, without an explicit regulatory mandate.
g) The existing provisions already permit the telecom service providers to do
away with hard copy of the bills if they obtain consent from subscribers for
receiving bills through e-mails. This position is equally applicable to the M-bill
option proposed in COAI representations. Consent of the subscribers for E-bill
or M-bill can thus be obtained by creating awareness about the environmental
concerns in a mission mode, like the campaign on forgoing cooking gas
subsidy.

2.6 During the discussions on representations of industry and their associations a

One page-bill was also proposed by the industry representatives/ Associations which
would replace the present detailed bills as default option. The list was found to be
restrained by a long list of mandatory items as prescribed by TRAI Direction dated 4th
May, 2007 issued from QoS Division. These mandatory provisions were equally
applicable to any type of bill provided to the subscribers of postpaid mobile services.
It implied that even if M-bill/e-bill was allowed as default option, the format would

9
 need to include all the mandatory items listed in the said Direction. The list of items
as mandated to be included in bills appears too elaborate to be captured even in one
single page of hard copy bill.

Additional inputs obtained by TRAI from the TSPs:

2.7 In order to gather more information regarding demand of e-bill by customers or
initiatives taken by the service providers to induce customers to switch to e-bill, TRAI
sought information from various telecom service providers through letter dated
09.07.2018. Responses received from TSPs were analyzed and it came out that
currently not much of the total postpaid subscriber base have have migrated to e-bill
and those who have opted for e-bill are mostly from urban areas than rural. The
information collected also indicate that there also have been cases of over-charging
of bill by many service providers. Table presented below gives brief of the responses
by TSPs:

Statement of Responses Provided by Telecom Service Providers on various

Queries raised by TRAI

Query raised by Operator 1 Operator 2 Operator 3 Operator 4 Operator 5

TRAI
Steps to provide Bill summary Go Green Sending bill Phone customers Subscribers
the e-bill to post through SMS; initiative has been summary can view last 6 have to
paid customers 3000 stores taken for Post- through SMS months bills by register email
using feature where customers paid Landline and to feature logging into app, by sending
phone. can walk in for Mobile phone but which is available an SMS code.
bill details; connections. does not show in 11 Indian
customers can detailed languages. A
call on 121 for bill invoice. detailed SMS
details; bills are stating the invoice
provided on email charges is also
if the customer sent to customers
with feature along with email.
phone opts in for
e-bill.
Incentives offered, No specific Discount of Rs Offering Facility of viewing No specific
if any, to incentives 10/- per bill is freebies to and download last incentives
subscribers opting allowed for Go subscribers 6 months
for e-bill as default Green. opting for E- statement of bill
option bill as default without incurring
option. any charges.
Incidence of bill- 0.41 Million for Four cases only Have been Because of fair 272 cases of
shocks/over-billing the month of receiving over- usage policy in all over billing
coming to TSP‟s August, 2018 billing the plans, the for QE June
knowledge complaints. monthly 2018
through consumption has
complaints been capped and
therefore any
consumer
complaint has not
been received yet.
10
 Under Plans with
Pay as you go,
subscribers are
charged at
discounted rate
and restricted
upto credit limit.
Whether any Not conducted Customers being Not conducted Consumer Not
surveys have been any survey so far persuaded for any survey so workshops are conducted
conducted to opting Go Green. far conducted to any survey
know about spread so far
customers‟ awareness, SMS/
preference of IP-messaging
receiving bills and campaigns help in
if so, a copy protecting the
thereof environment by
opting for e-bill
which has in
inducing people to
opt for electronic
bill.
Any other relevant 60% of postpaid Nil No other Additional Nil
inputs/reports/stu customers are relevant sources/channels
dy/best practices engaged on App information. have been
that TSP would which is single developed for
like to share points solution customers to help
for billing and keep them
other self service updated about
solutions. It their
shows that call/SMS/Data
customers are usage from time
moving toward to time.
available digital
platforms for self
service modes.

Printed bill on demand of prepaid customers:

2.8 To protect the interests of pre-paid mobile phone subscribers who are able to
view their balance after every usage, TRAI had directed that TSPs, on request from
any pre-paid mobile connection consumer for any period falling in the preceding six
months, shall supply such a consumer, at a reasonable cost not exceeding Rs. 50,
the information relating to itemized usage charges showing actual service usage
details in terms of all call data records including value added services, premium rate
services, roaming charges and their monetary value within 30 days of consumers‟
request. This is despite the fact that unlike post paid subscribers, pre-paid
subscribers are not supposed to get bill by virtue of the platform of service they are
using. This provision enables prepaid customers in making any complaint regarding
excess charging by submitting the hardcopy of the bill as a proof. One can argue that
the need of receiving the bill is much necessitated in the case of post paid scenario
where customers are being charged at the end of the month on the basis of usage.
11
Some may however also argue that if requirement of hard copy of the bill exists in
prepaid scenario for dispute resolution process then the necessity of the same in
postpaid cases scenario may also exist.

2.9 The next chapter deals with additional facts that may need to be factored in for
taking a holistic view on the subject.

12
 Chapter 3:

Demographic profile in terms of education, e-literacy, Age and

affordability of Smart Phone

In addition to the extant regulatory Provisions as mentioned in chapter 1 and the

chapter 2 detailing industry and consumer side arguments there are few other
relevant factors: Other important factors relevant in the context of electronic invoice
are e-literacy, elderly population and affordable access of Smart Phone. This chapter
provides inputs to the stakeholders on these aspects.

3.1 Education: It has been recognized that education is also a dividing factor on
internet use, with significant gaps between these with more and less education in all
countries surveyed by Pew Research Center including India10.

10
Pew Research Center, June, 2018, “Social Media Use Continues To Rise in Developing Countries, but Plateaus Across
Developed Ones”
13
3.2 E-literacy: As per UNESCO, e-literacy refers to awareness, skills,
understandings, and reflective approaches necessary for an individual to operate
comfortably in information-rich and IT-enabled environments. In a more generic
form, it can be defined as a skill set required to make use of the information, tools
or materials that are available online11. E-literacy is integral to capacity-building for
citizens to participate in modernizing governance and an effective way to advance
digital democracy12. It is observed that e-literacy is essential for the consumers for
being able to decipher the proposed e-bill.

3.3 Percentage of e-literate Population:

Developed and developing digital divide: Percentage of internet users has
increased more in developing countries than developed in recent years
reducing the digital divide. In 2005, the internet users accounted only 6%
of the world’s population and out of that 85% of them were in developed
countries13. In contrast to this, in 2016, internet users in developing
countries were 40% and in developed countries it was 81%14. Among this,
India contributes to 13% of the total internet users of the world15.
Note: Internet User = individual who can access the Internet at home, via any
device type and connection.

3.4 Elderly Population in India (60 years and above):

The size of the elderly population i.e. those who are aged 60 years or above was
10.4 crore constituting 8.6% of the total as per the census 2011. Out of 10.4 crore,
7.3 crore of elderly population constituting share of 70.19% were in rural areas.
The share shows consistently rising trend over the years16. Further it has been
recognised that globally, young people use the internet more than the older
generation17.In other words, India has a sizable population which is not very e-
savvy.

11
https://www.igi-global.com/dictionary/social-networking-sites-critical-language/37799
12
Prasad, A. (2015). E-Governance Policy For Modernizing Government Through Digital Democracy In India.
Vol. 2 (2012), pp. 183-203
13
Rao, A. (2005). Bridging Digital Divide: Efforts in India. Telematics and Informative 22 (2005) 361-375
14
International Telecommunication Union (ITU)
15
http://www.internetlivestats.com/internet-users/india/
16
Report on Elderly in India by Ministry of Statistics and Programme Implementation, Central Statistics Office
17
Pew Research Center, June, 2018, “Social Media Use Continues To Rise in Developing Countries, but Plateaus Across
Developed Ones”

14
3.5 Relevance of e-literacy in m-bill: Though developing countries like India
have made moderate progress in developing online services, the cost of establishing
computer and Internet networks and telecommunications infrastructure to serve the
huge population is still considerable (Prasad, 2015). It is important to analyze how
many people would switch to m-bill/e-bill services without any complication. Because
of the digital divide in India, anybody without internet access and smart phone
would not be able to use the m-bill/e-bill services and any development in this field
would be of no use to them. Internet access is a must before implementing any e-
bill/m-bill/e-governance provision and looking at the statistics in India, as of 2016,
only 34.8% of the whole population has internet access18. As majority of the
population is internet-less, it is important to upgrade the total number of internet
users in the country to prepare for the desired increase the digital transaction.

3.6 Smartphone Users in India: It is equally important to look at the total

percentage of smart phone users in India before changing any rule for default option
as m-bill or e-bill as most of the digital payments are made using the smart phones.
As per the report by IAMAI on Indian Mobile Phone Market, more than 75% of the
Indian population in 2015 still did not carry any smart phone. Also, as per
Counterpoint Research, currently only 46% of the total mobile users are smart

18
www.indiainternetusers.com
15
phone users which means that more than 50% of the demand is still for feature
phones in India19. As per the media reports, more than 55% of Indian population
live in rural areas where mobile phone is only used to make and take calls thereby
preferring a mobile phone which is cheap and consume less battery.
As per the survey conducted by Pew Research Center20 in 37 countries from
February 16 to May 8, 2017, Sub-Saharan Africa and India still lag in internet usage.
As per the survey results only one-in-four Indians reported using the internet or
owning a smart phone. It has also been analysed that ownership of smart phone still
lags in India, Indonesia and Africa despite of increasing levels of smart phone use. It
is prominent from the survey results that only 22%-25% of the adults in India use
internet. Graph 1 below shows use of internet by adults across 39 countries
surveyed:

Graph 1 Graph 2
Source: Spring 2017 Global Attitudes Survey. Q63 & Source: Spring 2017 Global Attitudes Survey. Q64 & Q65.
Q65. U.S. data from a Pew Research Center survey U.S. data from a Pew Research Center survey conducted
conducted Jan. 3-10, 2018. China data from Spring 2016 Jan. 3-10, 2018. China data from Spring 2016 Global
Global Attitudes Survey. PEW RESEARCH CENTER Attitudes Survey. PEW RESEARCH CENTER

19
mobilityindia.com
20
Pew Research Center, June, 2018, “Social Media Use Continues To Rise in Developing Countries, but Plateaus Across
Developed Ones”
16
Graph 2 highlights that though smart phone ownership is increasing in emerging
economies, then also it is the lowest in India. In India and Tanzania less than one
quarter reported owning smart phones which is the lowest among 12 out of 22
emerging countries surveyed for smart phone penetration.

3.7 Next chapter deals with the status of e-bills in the utilities services in India.

17
 Chapter 4:
E-billing in Utility Billing System:

The current chapter mentions in brief the trends in adoption of e-billing in other
utilities in India:

4.1: Credit Card Companies: While most of the credit card companies
encourage bill through e-mode, hard copy of the bill is also provided to customers as
default option. Credit card companies actively provide incentive to customers for
switching to e-bill.

4.2: Central Electricity Regulatory Commission (CERC): CERC is the key

regulator of power sector in India. CERC has not imposed any regulatory guidelines
for billing, so the general industry practice is to send the bill through hard copy to
the customers unless the customer opt for an e-bill.

4.3: Indraprastha Gas Limited (IGL): IGL is one of the leading gas distribution
companies. The practice followed by IGL for Billing is based on the meter readings
taken by the authorised IGL staff once in two months for the domestic
consumers. The bills are delivered at the customer's residence. The payment of
the bills can be made by using any of the payments modes specified under
'Payment Modes' in PNG section.

4.4: Mutual Funds: Mutual funds are required to dispatch certificates or

statements of accounts within five working days from the date of closure of the
initial subscription of the scheme. In case of open-ended schemes, a statement of
account is issued by the mutual fund within five working days from the date of
closure of initial public offer of the scheme and/or from the date of receipt of the
request from the unit holders. However, E-statements are encouraged.

18
 Chapter 5:
International Practices:

World has become a global village. Therefore, it has been considered important to
take a look at the provisions for paper bills in other telecom jurisdictions. A few
sample cases are given below:

5.1: The Office of Communications (OFCOM), UK: Most suppliers provide

at least a basic level of billing free by post. However, most of them made a specific
charge for itemized billing by post. However, the suppliers who provide broadband
service (irrespective of whether they provide voice telephony service) make charge
for sending any level of bill by post presumably because consumer has access to
online bills and is net-savvy21.

5.2: Federal Communications Commission (FCC), USA: Subscribers have an

option of either receiving the hard copy of the bill or get the details of the bill via
email. Service providers are directed to provide a toll-free number or numbers by
which subscribers may inquire or dispute any charges on the bill in case of hard copy
of the bill. Where the subscriber does not receive a hard copy of his or her telephone
bill, but instead accesses that bill only by e-mail or internet, the service provider
complies with this requirement by providing on the bill an e-mail or web site
address22.

5.3: Australian Communications and Media Authority (ACMA), Australia:

There is no default option of either receiving the bill in e-bill format or hardcopy
form. It depends on the customers how they want to receive the bill and make
payments thereafter as the information about the billing procedures and options are
made available to the customers before they sign up or purchase. The service
provider has to provide at least one free accessible format such as a bill via post
(hardcopy), email or through an online client account and advise whether additional
charges will be applicable to use other payment methods23 (e.g. credit card merchant
fees).

5.4: Commission for Communications Regulation (COMREG), Ireland: The

service providers can either send the hard copy of the bill or send the bill online or
via email. If the subscriber does not have the broadband or internet connection the
service provider must send the hard copy of the bill24.

21
https://www.ofcom.org.uk/advice-for-businesses/knowing-your-rights/gen-conditions
22
https://www.law.cornell.edu/cfr/text/47/64.2401
23
https://www.acma.gov.au/Home/theACMA/your-mobile-bill

24
https://www.comreg.ie/consumer-information/home-phone/billing-and-disputed-charges/
19
5.5: The Canadian Radio-television and Telecommunications Commission
(CRTC), Canada: Wireless Service Providers are required to provide the permanent
copy of the postpaid contract to the customers that is the hard copy of the contract
free of charge. It is up to the customer to switch to electronic copy of the contract25.

5.6: New Zealand: Most of the SIM providers in New Zealand send the bills to the
post paid customers via electronic mail. Bills are available for each billing cycle free
of charge by electronic mail only. If the subscriber wishes to receive the hard copy of
the bill then $2.50 is charged by Spark NZ every time the bill is sent by post 26.
2degreesmobile charges an amount from the customers if they wish to receive the
bill in other forms such as hard copy. However, the exact amount charged is not
mentioned by the service provider. It is also mentioned in the terms and conditions
of 2degreesmobile that it receives payments only by credit card, debit card, direct
debit or online banking and do not accept payment by cash, cheque or any other
method27.

5.7: Singapore: Telecom service providers in Singapore send the hard copy of the
bill, unless otherwise specified by the subscribers. For example, if a Singtel
subscriber requests to start receiving e-bill then Singtel after accepting the request
will make the bill available through its e-bill website and cease the dispatch of the
bill28. Similarly, another service provider, Start Hub stops sending the monthly copy
of the bill once the subscriber opts for e-bill service. This implies that post-paid
subscribers in Singapore, just like in India, receive hard copy of the bill unless opted
out by the subscribers themselves29.

5.8: Malaysia: Many big telecom service providers such as Telekom Malaysia and
Maxis30 send the bill via email and no hardcopy of the bill is sent to any post paid
subscriber. If the subscribers want the hard copy of the bill, Telekom Malaysia has
provided with the weblink wherein the subscribers can submit their personal details
and take the print out of the bill31.

5.9: Japan: To check whether the physical copy of the bill is received by the
subscribers in Japan or not, terms and conditions of billing, of three major telecom
service providers i.e. NTT Docomo, Softbank Group32 and KDDI33 were observed. It is
found that none of the above service provider issues the hard copy of the bill. All the

25
https://crtc.gc.ca/eng/archive/2013/2013-271.htm
26
https://www.spark.co.nz/help/other/terms/personalterms/sparkpostpaidagreement/#ouragreemen t
27
https://www.2degreesmobile.co.nz/termsofuse/mobile/pay-monthly/pay-monthly-terms-and-conditions/
28
https://www.singtel.com/terms-billing
29
http://www.starhub.com/content/dam/starhub/legal-notices-and-terms/consumer/consumer-general.pdf
30
https://www.maxis.com.my/en/personal/support/billing-and-payment/getting-your-bill/billing-choices/e-bill/e-billing-
question-2.html
31
https://unifi.com.my/mobile/postpaid/assets/doc/faq.pdf
32
https://cdn.softbank.jp/en/mobile/set/data/legal/spguide/pdf/notices.pdf

33
https://www.au.com/english/mobile/information/other/
20
post-paid subscribers have to check the bill issued on online billing information forum
of the service providers. However, NTT Docomo issues the physical invoice of the bill
on the request of the subscriber but charges an issuance fees34.

5.10 The preference for printed copies of other information and communication
sources such as news, magazines, books etc. has also been considered an important
factor even in developed countries to analyse the shift from printed copies to digital
copies of the bill. The debate to shift to digital versions of everything is still ongoing
in developed countries of the world. Key findings of the survey conducted by „Two
Sides‟ (carried out by leading research company Taluna) on „Print and Paper in a
Digital World‟ are listed below35:
 90% of the consumers believe that the right to choose how they receive
communications should be provided by service providers and financial
organizations and approximately 83% believe that they should not be charged
extra for opting printed bills or statements;
 Even in a developed country like USA, 73% of the consumers agreed that they
are being induced to switch to „paperless‟. Even if they receive the electronic
document from banks, service providers etc. consumers have to get a printed
copy at home if they need the hard copy as 68% of the consumers find it
easier to track their finances and expenses on printed bill. This implies that in
real it is not completely „paperless‟;
 72% of the consumers agreed that companies are inducing them to switch to
paperless documents not for better environment conditions but because the
sender wants to save money;
 71% of the consumers find it more comfortable to read news in a printed
newspaper as it provides a better understanding of the issue or story than
reading it online;
 Similarly, 73% of the consumers enjoy reading magazines and books in the
printed form than reading them on an electronic device.

5.10 After briefly mentioning the various aspects in Chapter 1 to 5 for ready
reference of the stakeholders, next chapter lists out the issues for consultation.

34
https://www.nttdocomo.co.jp/english/charge/bill_schedule/

35
Print and paper in a digital world, Two Sides North America, Inc. Retrieved from
https://www.twosides.info/survey2017/ (UK Key findings)

21
 Chapter-6

Issues for Consultation

(i) As per the extant provision of TTO (46th Amendment), provision of hard copy of
the bill or printed copy of the bill to postpaid subscribers is mandated as a
default option. Is there a need to change the extant default option, i.e.,
provision of paper bill without any charge to postpaid subscribers of Wire line
and (ii) Mobile services? Kindly support your answer with rationale.

(ii) As against the existing practice of issue of printed bill to postpaid subscribers of
(i) Wireline and (ii) Mobile service, unless a subscriber opts for electronic-bill (e-
bill), should e-bill now be made the default option? And if so, why?

(iii) If e-bill is made default option then how the bills would be made available to
Postpaid subscribers of (i) Wireline and (ii) Mobile services with (a). Subsribers
of Feature phones and (b). Subscribers who do not have e-mail facility.

(iv) If a subscriber opts for e-bill and requests for change the option to printed bills,
will there be a charge for providing the printed bill? Kindly provide reasons for
your answer.

(v) What could be the safeguards for subscribers who do not wish electronic bills
and prefer to get printed bills?

(vi) TRAI has mandated specified set of information to be printed on bills to

postpaid subscribers. If the printed bill is not issued, then how the specified set
of information will be conveyed to subscribers? Should the same be mandated
for e-bills also? Kindly support your comments with justification.

(vii) Any other issue relevant to the subject discussed in the consultation paper may
be highlighted.

22
 Annexure - A

TELECOM REGULATORY AUTHORITY OF INDIA

NOTIFICATION

New Delhi, the 24th January, 2008

THE TELECOMMUNICATION TARIFF (FORTY-SIXTH

AMENDMENT) ORDER, 2008

(No. 1 of 2008).

No. 301-36/2007-Eco. --- In exercise of the powers conferred upon the

Telecom Regulatory Authority of India under sub-section (2) of section 11,
read with sub-clause (i) of clause (b) of sub-section (1) of the said section, of
the Telecom Regulatory Authority of India Act, 1997 (24 of 1997), the
Telecom Regulatory Authority of India (TRAI) hereby makes the following
order further to amend the Telecommunication Tariff Order, 1999, namely:-

1. (1) This Order shall be called the Telecommunication Tariff (Forty-

sixth Amendment) Order, 2008.

(2) This Order shall come into force from the date of its publication
in the Official Gazette.

2. In Schedule I to the Telecommunication Tariff Order, 1999 (hereinafter

referred to as the principal Tariff Order ), for items 10 and 11 and entries
relating thereto, the following items and entries relating thereto shall be
substituted, namely :-

23
 Schedule – I

Basic Services (Other than ISDN)

ITEM TARIFF
“10. Tariff for itemized bills in
respect of long distance calls NIL

10A. Tariff for provision of hard

copy of the bill or printed copy of the
bill to the customer NIL
11. Other matters relevant to tariff
including billing cycle Forbearance

3. In Schedule II to the principal Tariff Order, after item 7 and entries

relating thereto, the following item and entry relating thereto shall be
inserted, namely:-

Schedule II

Cellular Mobile Telecom Service (CMTS)

ITEM TARIFF
“7A Tariff for provision of hard
copy of the bill or printed copy of
the bill to the customer NIL

[M. Kannan]
Advisor (Economic)
Telecom Regulatory Authority of India

24
Note.1. – The Telecommunication Tariff Order, 1999 was published in the
Gazette of India, Extraordinary, Part III, Section 4 under notification no.99/3
dated the 9th March, 1999, and subsequently amended by the following
notifications, namely:-

Amendment No. Notification No. and Date

1st 301-4/99-TRAI (Econ) dated 30.3.1999
2nd 301-4/99-TRAI(Econ) dated 31.5.1999
3rd 301-4/99-TRAI(Econ) dated 31.5.1999
4th 301-4/99-TRAI(Econ) dated 28.7.1999
5th 301-4/99-TRAI(Econ) dated 17.9.1999
6th 301-4/99-TRAI(Econ) dated 30.9.1999
7th 301-8/2000-TRAI(Econ) dated 30.3.2000
8th 301-8/2000-TRAI(Econ) dated 31.7.2000
9th 301-8/2000-TRAI(Econ) dated 28.8.2000
10th 306-1/99-TRAI(Econ) dated 9.11.2000
11th 310-1(5)/TRAI-2000 dated 25.1.2001
12th 301-9/2000-TRAI(Econ) dated 25.1.2001
13th 303-4/TRAI-2001 dated 1.5.2001
14th 306-2/TRAI-2001 dated 24.5.2001
15th 310-1(5)/TRAI-2000 dated 20.7.2001
16th 310-5(17)/2001-TRAI(Eco.) dated 14.8.2001
17th 301/2/2002-TRAI(Econ) dated 22.1.2002
18th 303/3/2002-TRAI(Econ) dated 30.1.2002
19th 303/3/2002-TRAI(Econ) dated 28.2.2002
20th 312-7/2001-TRAI(Econ) 14.3.2002
21st 301-6/2002-TRAI(Econ) dated 13.6.2002
22nd 312-5/2002-TRAI(Eco) dated 4.7.2002
23rd 303/8/2002-TRAI(Econ) dated 6.9.2002
24th 306-2/2003-Econ dated 24.1.2003
25th 306-2/2003-Econ dated 12.3.2003
26th 306-2/2003-Econ dated 27.3.2003
27th 303/6/2003-TRAI(Econ) dated 25.4.2003
28th 301-51/2003-Econ dated 5.11.2003
29th 301-56/2003-Econ dated 3.12.2003
30th 301-4/2004(Econ) dated 16.1.2004
31st 301-2/2004-Eco dated 7.7.2004

25
32nd 301-37/2004-Eco dated 7.10.2004
33rd 301-31/2004-Eco dated 8.12.2004
34th 310-3(1)/2003-Eco dated 11.3.2005
35th 310-3(1)/2003-Eco dated 31.3.2005
36th 312-7/2003-Eco dated 21.4.2005
37th 312-7/2003-Eco dated 2.5.2005
38th 312-7/2003-Eco dated 2.6.2005
39th 310-3(1)/2003-Eco dated 8.9.2005
40th 310-3(1)/2003-Eco dated 16.9.2005
41st 310-3(1)/2003-Eco dated 29.11.2005
42nd 301-34/2005-Eco dated 7.3.2006
43rd 301-2/2006-Eco dated 21.3.2006
44th 301-34/2006-Eco dated 24.1.2007
45th 301-18/2007-Eco dated 5th June, 2007.

Note 2. – The Explanatory Memorandum explains the objects and reasons

for the Telecommunication Tariff (Forty – sixth Amendment) Order, 2008.

26
 Explanatory Memorandum

It has come to the notice of the Telecom Regulatory Authority of

India (TRAI) that a mobile service provider has offered a post-paid tariff
plan in which the subscribers are being given bills through SMS or email.
The hard copy of the bill is available to the subscribers only on payment of a
fixed amount as determined by the operator.

2. The Authority has examined the issue keeping in view the provisions
in the Indian Telegraph Rules, 1951, licence agreements for Cellular Mobile
Telecom Service (CMTS), Unified Access Service, National Long Distance
(NLD) and International Long Distance (ILD) services relating to billing and
customer service.

3. Under the provisions of the Indian Telegraph Rules, 1951, the charges
for calls in message rate and measured rate system shall become payable on
presentation of a bill. It also stipulates that, any notice, bill or demand from
the Telegraph authority for any fee or charges due from a subscriber may be
served by delivery to the subscriber, or by sending it by post to the address
of the subscriber or by leaving it at the premises or upon which the apparatus
is installed. Rule 439 of the Indian Telegraph Rules, 1951 reads as under:-

“439. Charges when payable

Charges for calls in message rate or measured rate system shall
become payable on presentation of a bill therefor. The periods for which bill
shall be prepared and the dates by which they shall be payable shall be fixed
by the Telegraph Authority.”

27
Rule 442 of the Indian Telegraph Rules, 1951 reads as under:-

“442. Service of notice and bills

Any notice, bill or demand from the Telegraph Authority for any fee
or charges due from a subscriber may be served by delivery to the
subscriber, or by sending it by post to the address of the subscriber or by
leaving it at the premises in or upon which the apparatus is installed.”

Besides, CMTS licence agreement (Condition 7 in Part I of Schedule II) and

the Unified Access Service license agreement (Clause 30.4) also, inter-alia,
stipulate that it shall be the responsibility of the licensee to issue or cause to
be issued bills to its subscribers for use of the service. As per these licensing
conditions, the billing system of the licensee shall be able to generate the
billing information, in adequate details, to ensure satisfaction to the
customer about the genuineness of the bill. The licence agreements for these
services also mandate that the directions of TRAI, from time to time, in this
regard shall apply.

4. Taking note of the above position, the Authority initiated a

consultation process on the 1st January, 2008 by circulating a draft Tariff
Amendment Order, alongwith a background note and a press release,
inviting comments of stakeholders on the proposal for amending the
Telecommunication Tariff Order to incorporate an explicit provision for
providing bill in hard copy free of cost to all post paid subscribers.

28
5. Various stakeholders including Service Providers, Consumer
Organizations and Associations of Service Providers had responded to this
consultation process with written comments. Stakeholders have in general
overwhelmingly welcomed the proposal of the Authority for mandating
provision of hard copy / printed copy of the summary bill to the post paid
consumers free of cost. All Service Providers who have responded to the
consultation process, have stated that they were already giving hard copy of
the bill free of cost to their post-paid customers. Some of the Service
Providers and the Associations of Service Providers have suggested that the
amendment should also provide clarity as regards the provision of printed
copies of the itemized bills for local calls and Short Message Service (SMS)
to consumers. They have suggested that the tariff amendment order may
clarify that itemized bills for local calls and SMS are to be provided to the
consumers at some cost and that the charges for such itemized bills for local
calls and SMS should be kept under forbearance. Some of them have also
suggested that even after getting bills in electronic form, if a customer insists
for a hard copy of the bill, then it should be at a cost. It has also been
suggested that, considering the convenience of electronic bills to a large
section of subscribers, hard copy of bills should not be mandated and choice
of receiving bills, hard copy or soft copy, should be left to the subscribers.

6. Consumers and Consumer Organisations have generally commented

in favour of the proposal of the Authority by stating that such a move would
go a long way in educating and informing laymen – consumers to know the
details of their bills. One Industry Association has submitted that, as regards
the low end post-paid customers (having bill amount of say Rs.100/-), SMS

29
and e-mail should be considered as valid way for informing the customers of
the dues payable by them.

Analysis:-

7. The bill represents the true extent of the service actually provided by
the service provider and also the details about the service and conditions,
which are available to the subscribers.

8. Some of the purposes of issuing or obtaining the telephone bills

through hard copy, inter-alia, are to ----

a) understand and satisfy oneself about the genuineness of the bill;

b) facilitate making of payment;
c) verify the charges incurred by the consumer;
d) monitor usage or expenditure by consumer.

9. Recently, TRAI has undertaken a detailed study on the presentation of

the bills to the consumers and after a limited consultation, issued a Direction
vide No. 303-4/2007-QoS, dated the 4th May, 2007 specifying various
guidelines as to how the bill should be presented to the consumers. It was
mandated that bill must contain certain useful information to the consumers
in addition to the amount of the bill. The Authority had also issued the
Telecom Consumers Protection and Redressal of Grievances Regulations,
2007 dated 4th May 2007 in which the Authority has envisaged provision of
usage details even to the pre-paid mobile users.

30
10. The Authority in its Direction vide F.No. 303-4/2007-QoS dated the
4th May, 2007 has specified a number of information, which are useful to the
consumers, to be captured in the bill. Such information cannot be easily,
conveniently and comprehensively captured in short message service (SMS)
and bill sent through SMS would not give sufficient clarity. Most of the
consumers who own a phone may not be having access to computer and
internet to obtain the bill through e-mail. Access to e-mail is normally not
available to the persons who are in the low-income category. It is, therefore,
in the interest of the consumers that the service providers give the bills in an
understandable form to their consumers. It would, therefore, not be
consumer friendly to permit service providers to levy extra charges for
providing hard copy of the bill.

11. The Authority has noted that the service providers of other sectors
such as Electricity Corporations, Water Utilities services, and Financial
Institutions, etc., are not charging any amount for providing the hard copy of
the bill.

12. For any services, the subscribers have the right to know and verify the
charges levied by the service providers without any exception. Thus,
provision of a fixed sum for providing hard copy of the bill is anti-customer.
In the views of the Authority, a classification of low end subscribers based
on monetary value suggested by the Industry Association is likely to be
termed as arbitrary as usage and bill values are relative in nature. Further,
‘low-end’ customers are the ones who cannot generally afford to have access
to computer / internet and, therefore, it is this category of customers who
needs protection.

31
13. The Authority after careful consideration of the provisions relating to
billing in the Indian Telegraph Rules, 1951, license agreements for Cellular,
Unified Access, NLD and ILD licenses and also the views expressed by
stakeholders is of the view that it is necessary to mandate the service
providers to provide hard copy of the bill to its post-paid subscribers free of
cost. However, if any customer opts for receipt of the bill through e-mail,
instead of hard copy, the service providers can supply the same after
obtaining explicit consent from the consumers. In all other cases, the service
provider must ensure that the bills are generated and delivered to the
consumers in printed form free of cost.

14. It is clarified that it has already been mandated to provide itemized

bill in respect of long distance calls free of cost on request. As regards the
suggestion of the service providers that the Tariff Amendment Order may
clarify that itemized bills for local calls and SMS are to be provided to the
consumers at some cost and that the charges for such itemized bills for local
calls and SMS should be kept under forbearance, it is clarified that the
existing provisions of telecommunication tariff order are clear that itemized
bills in respect of long distance calls are to be provided to the subscribers
free of cost. However, the issue of providing itemized bills in respect of
local calls and SMS remains already under forbearance. The requirement
now being mandated is only in respect of the basic / summary bill and the
itemized bill in respect of long distance calls are to be provided to subscriber
free of cost. This being the position the Authority does not deem it
necessary to provide for any specific provision in the tariff order for
itemized bill for local calls / SMS.

32
15. This amendment to the principal Tariff Order by the
Telecommunication Tariff (Forty-sixth Amendment) Order, 2008
incorporates the decision of the Authority that the telecom customers must
get the bill in a printed paper form without any extra charge from them.

33
 Annexure - B

I.
'. !

Date: 21.05.2018

To,
Mr. R. S. Sharmaji,
Chairperson TRAIl
Telecom Regulatory Authority of India,
Mahanagar Doorsanchar Bhawai..
(Next to Zaki r Hussain College)
[awaharlal Nehru Marg (Old Minto Road)
New Delhi: 110002

Sub: - Amendment of TRAI (Telecom Regulatory Authority of India] ruling of

Sending printed bills to its consumers. - Regarding.

Respected Sir,
This is to bring to your kind notice that Four Billion Trees are cut down
worldwide each year for paper, representing about 35% of all harvested Trees.
One Tree makes around 8000 sheets of paper. On an Average it is
seen/studied/observed that around Eighty Thousand Trees are cut per year just
to generate printed bills for BSNL customers alone. And if you add to that
various other departments such as

Telephone and Mobile Bills by various Telecom Operators such as

MTNL, Vodafo le, [io, Airtel etc

.The number 0 I Trees being cut is mind boggling.

With the verwhelming positive response for our Hori'ble PM's Digital India
Mission and adaptation of the same by the people of India, we can further save
paper by sendirg these monthly bills vide ernail, SMS or any other official digital
mode available for promoting paperless working.
It has c9me to my notice that there is a regulation of TRAI(Telecom
Regulatllry Aut rority of India) vide para 13 of Telecommunication Tariff (Forty
:'Sixth Amendme It) Order, 2008 dated 24th January, 2008, (Copy attached for ready
.,L,tference please) that requires printing of bills 2S mandatory. Based on these
~lIidelj]les MTNI & BSNL landline and Mobile bills arc issued in hard copies to its

34
. -

I.

r,
! consumers/customers. You will appreciate that this ruling was made in 2008 and
India has progressed in leaps and bounds in the last four years under the able hand
of our esteemed PM Shri Narendra Modi Ji and his Digital India Mission. Today
most Indians carry a mobile.

I earnestly request you to change this regulation( framed in 2008), such that it
States each Telecom Provider has to send bills by email/SMS/Digital media
only and that it should be mandatory. Any customer desiring for printed
would have to request for the same in writing. To discourage printed bills, such
customers should pay a nominal fee.

This will at least be a start and the above will help in saving the environment
along with expenditure cost to the Government ofIndia in following ways.
1) Help in reducing generation of paper waste and e-waste.
2) Conservation of nature and perseverance of its natural resources .

. The Customer can very easily get an SMSwith a link to facilitate payments/or he
can go to the nearest service center to make the payments. Details can be worked
out by concerned departments.
Thanking you.

35