TRAI Finalizes Key Guidelines on M2M Critical Services and SIM Ownership Transfer

Recognizing the growing reliance on M2M communications in critical applications, TRAI has recommended the adoption of a “twin-test” criteria to identify critical IoT services.

The Telecom Regulatory Authority of India (TRAI) has officially released its comprehensive set of recommendations on "Issues Related to Critical Services in the M2M Sector, and Transfer of Ownership of M2M SIMs." These guidelines mark a significant regulatory milestone aimed at reinforcing India’s Machine-to-Machine (M2M) and Internet of Things (IoT) ecosystem.

This move comes after the Department of Telecommunications (DoT) requested TRAI to re-evaluate and update its previous 2017 recommendations in light of the evolving technological and national needs. The initiative is expected to provide a structured regulatory framework supporting critical services across numerous verticals like healthcare, public safety, automotive, smart cities, utilities, and agriculture.

Background and Stakeholder Engagement

On January 1, 2024, the DoT wrote to TRAI invoking Section 11 of the TRAI Act, 1997, and sought updated recommendations addressing two primary concerns:

1. Identification of Critical Services in the M2M Sector

2. Transfer of Ownership of M2M SIMs

In response, TRAI released a consultation paper on June 24, 2024, to invite industry-wide feedback. A total of 16 comments and one counter-comment were received from a wide range of stakeholders including telecom service providers, technology companies, and industry bodies. An open house discussion, held virtually on October 24, 2024, further helped shape the final recommendations based on collective inputs and TRAI’s independent analysis.

Defining Critical IoT Services: A Twin-Test Framework

Recognizing the growing reliance on M2M communications in critical applications, TRAI has recommended the adoption of a “twin-test” criteria to identify critical IoT services. A service should be classified as ‘critical’ if:

1. It demands ultra-reliable, low-latency M2M connectivity with extremely high availability, and

2. Any disruption in the M2M connectivity would lead to severe consequences impacting national security, economic stability, public health, or public safety.

This classification aims to help regulatory bodies and ministries proactively recognize essential services and ensure their reliability through strict Service Level Agreements (SLAs) with telecom service providers.

Institutional Mechanism and Sectoral Collaboration

To ensure accurate classification and oversight of critical IoT services, TRAI has recommended:

• That respective ministries and regulatory bodies should be entrusted with the task of identifying critical services within their domains.

• The Department of Telecommunications (DoT) should create an institutional support mechanism to guide and assist these agencies in the classification process.

Technology-Agnostic Approach to Critical Services

TRAI strongly advocates a technology-neutral approach to promote innovation and flexibility. It recommends that any wireless or wired M2M communication technology, regardless of whether it uses licensed or unlicensed spectrum, may be deployed for critical IoT services as long as it meets the necessary performance benchmarks in terms of latency, availability, and reliability.

Emphasis on Security and Privacy in Critical M2M Deployments

With IoT devices becoming ubiquitous, the need for robust security and privacy safeguards has intensified. TRAI emphasizes that M2M communication modules embedded in IoT devices pose potential vulnerabilities due to their access to public telecom networks and the Internet.

To mitigate these concerns, TRAI recommends:

• All M2M modules used in critical sectors, as identified by the National Critical Information Infrastructure Protection Centre (NCIIPC), should be subjected to the Mandatory Testing & Certification of Telecommunication Equipment (MTCTE).

• This certification process should be phased and progressive, starting with the most sensitive sectors.

Recommendations on M2MSP Licensing and SIM Ownership Transfers

In an effort to streamline operations in the rapidly expanding M2M space, TRAI has laid out guidelines to simplify the transfer of M2M Service Provider (M2MSP) registrations or authorizations during:

• Mergers

• Demergers

• Acquisitions

• Other business restructuring scenarios

Further, recognizing the practical necessity for SIM reallocation, TRAI also recommends the DoT to:

• Introduce an enabling provision for transferring the ownership of M2M SIMs from one authorized entity to another, thereby improving business continuity and operational flexibility.

Next Steps and Contact Information

These far-reaching recommendations are now available for public and institutional review on the TRAI official website. They set a solid regulatory foundation for India’s evolving digital infrastructure and are likely to be integrated into national policy following review by the DoT.

For further queries or clarifications, stakeholders can contact:

Shri Akhilesh Kumar Trivedi Advisor (Network Spectrum & Licensing), TRAI 📞 +91-11-20907758 📧 advmn@trai.gov.in

TRAI’s updated recommendations not only reflect the pressing need to regulate and secure India’s critical digital infrastructure but also position the country to harness the full potential of IoT and M2M technologies. By laying out clear definitions, governance mechanisms, and technical standards, TRAI aims to ensure that services of critical national importance are supported by secure, reliable, and scalable connectivity frameworks.