TRAI Seeks Input on Foreign SIM/eSIM Use in Exported IoT Devices

TRAI’s initiative aims to establish a clear, forward-looking, and secure policy for this segment while safeguarding national security and ensuring proper licensing oversight.

In a significant step towards streamlining regulatory oversight in the Internet of Things (IoT) and Machine-to-Machine (M2M) communication ecosystem, the Telecom Regulatory Authority of India (TRAI) has released a consultation paper titled “The Regulatory Framework for the Sale of Foreign Telecom Service Providers’ SIM/eSIM Cards for Use in M2M/IoT Devices Meant for Export Purposes.”

This move responds to a formal request by the Department of Telecommunications (DoT), Ministry of Communications, Government of India, made via a reference dated 17th September 2024. The DoT had sought TRAI’s recommendations under Section 11(1)(a) of the TRAI Act, 1997, specifically regarding the terms and conditions for issuing and renewing No Objection Certificates (NOCs) for the import and sale of foreign SIM/eSIM cards intended solely for M2M/IoT devices being exported out of India.

The Growing Relevance of M2M/IoT in India’s Export Landscape

The backdrop of this consultation is India’s rapidly growing electronics and IoT device manufacturing ecosystem. As Indian companies manufacture increasing volumes of smart meters, automotive telematics systems, industrial automation modules, and wearable technologies for global markets, the use of foreign SIM/eSIMs embedded during manufacturing—especially to enable overseas connectivity post-export—has become commonplace.

Currently, ambiguity in regulatory policy around the use of these foreign network access elements has led to bottlenecks for exporters. TRAI’s initiative aims to establish a clear, forward-looking, and secure policy for this segment while safeguarding national security and ensuring proper licensing oversight.

Key Focus Areas in the Consultation Paper

TRAI’s paper outlines several important aspects, inviting wide stakeholder engagement to guide policy formulation:

• Eligibility and Conditions for NOC Grant/Renewal: Guidelines for entities that wish to import or sell foreign SIM/eSIM cards for pre-embedded use in export-bound devices.

• Regulatory Safeguards: Recommendations on maintaining traceability, security compliance, lawful interception capabilities, and compliance with international telecom norms.

• Operational Modalities: Processes to verify end-use of devices, audits of sales and export, and restrictions to ensure the foreign SIM/eSIMs are not used within Indian territory.

• Scope of Use: Whether the policy should include various sub-categories of IoT devices (like automotive, industrial, consumer) and whether pre-activation is permitted before shipping abroad.

• Coordination with International Providers: Frameworks to ensure accountability from foreign telecom service providers involved in provisioning these SIM/eSIMs.

Invitation for Comments and Counter-Comments

TRAI has called upon all stakeholders—including telecom operators, IoT device manufacturers, M2M service providers, exporters, industry associations, and technology experts—to submit their written comments on the issues raised in the consultation paper.

• Deadline for Comments: 1st August 2025

• Deadline for Counter-Comments: 18th August 2025

Submissions are encouraged in electronic format for ease of processing. Inputs may be sent via email to Shri Akhilesh Kumar Trivedi, Advisor (Networks, Spectrum & Licensing), TRAI, at advmn@trai.gov.in. Stakeholders seeking clarification may reach out to him via telephone at +91-11-20907758.

A Step Toward a Balanced, Export-Friendly Policy

This consultation reflects the regulator’s intent to strike a balance between industry facilitation and regulatory vigilance. It recognizes the importance of creating predictable policies to support “Make in India for the World” while ensuring that critical telecom infrastructure remains secure and compliant.

By initiating this dialogue, TRAI aims to evolve a transparent and inclusive regulatory framework that keeps pace with the global expansion of M2M and IoT deployments, while also protecting India's domestic communication networks.

The full text of the consultation paper is available on TRAI’s official website: www.trai.gov.in.