TRAI Recommends New Regulatory Framework for Use of Foreign SIM/eSIM Cards in Export-Oriented IoT and M2M Devices
TRAI noted that M2M communication and IoT technologies are increasingly central to critical infrastructure sectors such as energy, transportation, water management, agriculture and manufacturing.
New Delhi, December 31: The Telecom Regulatory Authority of India (TRAI) on Tuesday released its recommendations on creating a dedicated regulatory framework for the sale and use of foreign telecom service providers’ SIM and eSIM cards in Machine-to-Machine (M2M) and Internet of Things (IoT) devices meant exclusively for export.
The recommendations were issued in response to a reference from the Department of Telecommunications (DoT) under the Ministry of Communications, which had sought TRAI’s views on the terms and conditions for issuing and renewing no-objection certificates (NOCs) for importing and selling foreign SIM/eSIM cards for export-focused M2M/IoT applications.
Need for a new framework
TRAI noted that M2M communication and IoT technologies are increasingly central to critical infrastructure sectors such as energy, transportation, water management, agriculture and manufacturing. Indian manufacturers producing smart meters, connected vehicles and industrial sensors often need to embed foreign SIM or eSIM cards so that devices can operate seamlessly in destination countries.
At present, India lacks a formal regulatory framework governing the sale of such foreign SIM/eSIM cards for export-only devices. TRAI said an enabling framework is necessary to ensure regulatory clarity, facilitate exports and address national security considerations.
Key recommendations
Among the key proposals, TRAI has recommended the introduction of a light-touch authorisation regime under the Telecommunications Act, 2023. The new authorisation is proposed to be called “International M2M SIM Service Authorisation.”
Under the recommendations:
- The authorisation should be granted online through a digitally signed, auto-generated process.
- Any company registered under the Indian Companies Act would be eligible to apply.
- There should be no entry fee, minimum equity requirement, net-worth condition, bank guarantee or authorisation fee.
- A one-time application processing fee of ₹5,000 has been proposed.
- The authorisation should be valid for 10 years.
TRAI has also recommended that foreign SIM/eSIM cards embedded in M2M/IoT devices may be temporarily activated in India for testing purposes for up to six months.
Enabling exports and global competitiveness
To unlock market potential for Indian exporters and importers in the M2M and IoT segment, TRAI has suggested that DoT coordinate with other central ministries, including finance and commerce, to put in place a clear regulatory mechanism. This would enable both the import of foreign SIM/eSIM cards for export-oriented devices and the export of Indian telecom service providers’ SIM/eSIM cards for use in imported devices.
TRAI said the proposed framework would support the government’s Make in India initiative by making Indian-manufactured IoT and M2M products more competitive in global markets. The regulator noted that predictable and simplified regulation would help Indian enterprises compete with established international players in the rapidly growing IoT ecosystem.
Consultation process
The recommendations follow a detailed consultation process initiated in July 2025, during which TRAI sought stakeholder comments and held an open-house discussion in September. Based on feedback from nine stakeholders and further analysis, the regulator finalised the proposals.
The full recommendations have been published on TRAI’s official website.
