TRAI issues framework for foreign SIM/eSIM use in M2M–IoT devices meant for export

To develop a robust and inclusive framework, TRAI issued a Consultation Paper on 4 July 2025 seeking comments and counter-comments from stakeholders.

The Telecom Regulatory Authority of India (TRAI) has released its much-awaited recommendations on the regulatory framework governing the sale of foreign telecom service providers’ SIM and eSIM cards for use in Machine-to-Machine (M2M) and Internet of Things (IoT) devices manufactured in India for export markets. The framework aims to support India’s expanding IoT manufacturing ecosystem while ensuring regulatory clarity, security compliance and ease of doing business.

The Department of Telecommunications (DoT), through a letter dated 17 September 2024, 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 embedded in export-bound devices.

Consultation Process and Stakeholder Engagement

To develop a robust and inclusive framework, TRAI issued a Consultation Paper on 4 July 2025 seeking comments and counter-comments from stakeholders.

• Nine stakeholders responded with detailed inputs.

• An Open House Discussion (OHD) was held on 25 September 2025 through online mode.

After examining stakeholder responses and conducting its own analysis, TRAI finalised the recommendations now released publicly.

Why a Regulatory Framework Was Needed

M2M and IoT technologies are transforming the infrastructure landscape across sectors such as energy, transportation, water management, manufacturing and agriculture. Devices like smart meters, connected cars, GPS modules, industrial sensors and smart appliances often require SIM or eSIM cards from foreign telecom operators to function in the destination country after export.

However, India lacked a dedicated regulatory framework to govern the sale, activation and handling of these foreign SIM/eSIM cards. The absence of clear rules created compliance challenges, security concerns, and operational hurdles for manufacturers aiming to integrate foreign connectivity profiles into export-bound devices. The recommended framework addresses these gaps and supports India’s ambition to become a global hub for IoT manufacturing.

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Key Recommendations from TRAI

1. Light-Touch Authorisation under the Telecommunications Act, 2023

TRAI has recommended that the sale of foreign SIM/eSIM cards for export-bound M2M/IoT devices be regulated under a new light-touch authorisation called:

“International M2M SIM Service Authorisation”

This authorisation approach aims to ensure regulatory oversight without imposing heavy compliance burdens.

2. Fully Online Authorisation Process

• The authorisation should be issued online, with digitally signed, auto-generated certificates.

• This ensures transparency, simplicity and minimal procedural delays.

3. Eligibility and Fee Structure

Any company registered under the Indian Companies Act should be eligible to apply.TRAI has recommended zero financial barriers, including:

• No Entry Fee

• No Minimum Equity Requirement

• No Minimum Net Worth Requirement

• No Bank Guarantee Requirement

• No Authorisation Fee

The only payable fee is an Application Processing Fee of ₹5,000, and the authorisation should remain valid for 10 years.

4. Activation of Foreign SIM/eSIMs in India for Testing

To support manufacturers’ testing and quality assurance processes, TRAI recommends allowing foreign SIM/eSIM cards to be activated within India for up to six months solely for testing purposes.

5. Coordinated National Framework for SIM/eSIM Import and Export

To harness the growing global market for IoT-enabled devices, TRAI has suggested that DoT coordinate with other central ministries—especially the Ministry of Finance and Ministry of Commerce—to establish a clear regulatory pathway for:

• Import of foreign SIM/eSIM cards for M2M/IoT devices meant for export

• Export of Indian SIM/eSIM cards for M2M/IoT devices meant for import

This approach unlocks market potential and improves global competitiveness for Indian manufacturers.

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Supporting India’s Make in India and IoT Leadership Goals

TRAI emphasised that the recommended framework will strengthen India’s position in the global IoT marketplace by:

• Promoting local manufacturing for international markets

• Providing regulatory certainty to device manufacturers

• Addressing security concerns through structured authorisation

• Making Indian IoT-enabled products more competitive internationally

By easing the process of embedding foreign telecom profiles into export-oriented devices, the regulatory structure will help Indian enterprises stand shoulder-to-shoulder with global manufacturers.

TRAI’s full recommendations are available on its official website. For further details, stakeholders may contact Shri Akhilesh Kumar Trivedi, Advisor (Networks, Spectrum and Licensing), TRAI, at +91-11-20907758.