TRAI issues revised guidelines for M2M SIM ownership and critical IoT services

The Telecom Regulatory Authority of India (TRAI) has released its recommendations on the transfer of ownership of M2M SIMs and the provision of critical services within the M2M industry. These recommendations follow a request from the Department of Telecommunications (DoT) on 1 January 2024, seeking a review of TRAI’s earlier guidance issued in September 2017.

TRAI has proposed a technology-agnostic approach for the delivery of essential IoT services. According to a statement from the Ministry of Communications on Tuesday, 22 April 2025, "TRAI has specifically recommended that any wireless M2M communication technology whether operating on licensed or unlicensed spectrum or any wired M2M communication technology should be permitted for the provision of critical IoT services, provided it meets the prescribed service performance benchmarks."

Given the rapid proliferation of IoT devices, the regulator has stressed the need for stringent security and privacy measures. The National Critical Information Infrastructure Protection Centre (NCIIPC) has recommended that M2M communication modules integrated into IoT devices used in critical sectors be gradually brought under the scope of the Mandatory Testing and Certification of Telecommunication Equipment (MTCTE) regime.

“To address security and privacy concerns relating to IoT devices, particularly those used in critical sectors, TRAI has recommended that M2M communication modules embedded in or connected to all IoT devices, capable of being linked to telecom networks and deployed in sectors designated as critical by the NCIIPC, be brought under the MTCTE framework in a phased manner,” the statement read.

Background

To gather stakeholder input, TRAI issued a consultation paper in June 2024, receiving 16 responses and one counter-comment. A virtual open house discussion was subsequently held in October 2024.

Recognising the increasing significance of M2M communication in sectors such as public safety, smart cities, healthcare, utilities, automotive, finance, surveillance, and agriculture, TRAI has proposed a structured framework for defining "critical IoT services." Services requiring highly reliable, low-latency connectivity with high availability, and where any disruption could adversely impact public health, safety, national security, or the economy should, according to TRAI, be designated as critical.

TRAI recommends that the relevant ministry or regulatory authority determine such classifications, in consultation with the Department of Telecommunications. It has also proposed that the DoT establish an institutional mechanism to facilitate this process.

The SIM ownership model 

In terms of SIM ownership, TRAI has advised the creation of a regulatory framework that allows for the transfer of M2M Service Provider (M2MSP) registrations in cases of mergers, acquisitions, or demergers. It has further recommended that authorised entities be permitted to transfer ownership of M2M SIMs.

These proposals aim to strengthen the legal and regulatory foundation of India’s evolving M2M and IoT ecosystem, ensuring service reliability, enhanced security, and business continuity across critical sectors.