Background
On 23 June 2021, the Department of Telecommunications (DoT)
issued the Revised Other Service Provider (OSP) Guidelines (Revised
Guidelines), in supersession of the New OSP Guidelines that were
released on 5 November 2020 (Old Guidelines).
The Revised Guidelines define an OSP as an entity that provides
voice-based Business Process Outsourcing (BPO) services to
customers located world-wide, including in India. Voice based BPO
services means call centre services, where customers access the
network of OSP through public switched telephone network (PSTN).
The distinction between international and domestic OSP in the Old
Guidelines has been done away with.
One of the objectives of the Revised Guidelines is to ensure
that toll-bypass does not take place. Toll bypass means
transmission of PSTN calls, be it between India and foreign country
or between two cities in India, using own network of an OSP. It
appears that "own network" referred to in the
