DOT OSP Registration & Statutory Annual Compliance

In the modern digital economy, any corporate entity in India that provides IT-Enabled Services (ITES), Business Process Outsourcing (BPO), Knowledge Process Outsourcing (KPO), call center operations, tele-banking, tele-medicine, e-commerce customer support, or network operations using telecom resources must mandatorily comply with Department of Telecommunications (DoT) regulations. Historically known as OSP (Other Service Provider) Registration, the regulatory framework underwent a massive, business-friendly revolution with the New OSP Guidelines issued by the Ministry of Communications in November 2020 and revised in June 2021. Under the new regime, the Government abolished the cumbersome license requirements, bank guarantees, and statutory processing fees—replacing them with a streamlined, digital OSP Registration and self-declaration compliance model on the DoT Saral Sanchar portal.

While the new guidelines significantly liberalized work-from-home (WFH) and work-from-anywhere (WFA) operations, statutory compliance remains strict. OSPs are broadly categorized into two classes: Domestic OSPs (providing services to clients within India) and International OSPs (providing services to clients located abroad). To maintain active registration and avoid severe telecom penalties, every registered OSP must strictly adhere to network routing architecture rules—ensuring there is no illegal toll bypass or interconnection between domestic and international telecom networks without DoT approval. Furthermore, every registered entity must submit an Annual Return to the DoT stating their active OSP centers, employee headcount, and telecom resource utilization. At IPRO, our telecom regulatory consultants and corporate lawyers provide an end-to-end DoT OSP solution—managing network diagram verification, Saral Sanchar portal registration, EPABX/cloud PBX compliance advisory, and annual statutory filings.

To obtain and maintain a valid DoT OSP Registration under the New OSP Guidelines 2020/2021, the applicant business and its telecom infrastructure must meet specific statutory eligibility requirements:

• Incorporated Corporate Structure Mandatory: OSP registration can only be granted to a company incorporated under the Companies Act, 2013 (or 1956) or a Limited Liability Partnership (LLP) registered under the LLP Act, 2008. Sole proprietorships, traditional partnership firms, and NGOs are not eligible for OSP registration. • ITES / BPO Objectives in MoA: The Memorandum of Association (MoA) of the company or the LLP Agreement must explicitly contain objectives authorizing the business to conduct IT-enabled services, BPO, KPO, call center, or telecommunication-based outsourcing activities. • Authorised Telecom Resources Only: The OSP must procure all telecommunication resources (PSTN lines, ISDN PRI, MPLS, leased lines, SIP trunks) exclusively from DoT-licensed Authorised Telecom Service Providers (TSPs) such as Airtel, Jio, Tata Communications, or BSNL. • Strict Network Separation (No Toll Bypass): If an entity operates both Domestic and International OSP centers from the same premises, strict logical or physical network separation must be maintained. Interconnecting international data/voice streams with the Indian domestic public switched telephone network (PSTN) is a criminal toll bypass offense under the Indian Telegraph Act. • Maintenance of Call Detail Records (CDR): Under statutory security rules, every OSP must preserve complete Call Detail Records (CDR), system logs, and IP routing logs of all customer interactions for a minimum statutory period of one (1) year for inspection by DoT or security agencies.