TRAI on eSIMs: New Guidelines for M2M Communication

The Telecom Regulatory Authority of India (TRAI) has issued recommendations for the implementation of embedded SIMs (eSIMs) in M2M communication.It aims to achieve improvements in security and efficiency within M2M networks across various sectors.

Rashi Grover
New Update
A SIM chip placed on a computer motherboard.

The image is a close-up of a circuit board, showcasing sim chip,various electronic components and circuitry.

The Telecom Regulatory Authority of India (TRAI) has taken a significant step towards modernizing Machine-to-Machine (M2M) communication in the country.  Their recently released recommendations on the "Usage of Embedded SIM for Machine-to-Machine Communications" aim to pave the way for the widespread adoption of embedded SIMs (eSIMs) in M2M devices.


The Department of Telecommunications (DoT) requested recommendations from the Telecom Regulatory Authority of India (TRAI) regarding the utilization of embedded SIM for Machine-to-Machine (M2M) communications through a letter dated 09.11.2021, as per the TRAI Act, 1997. 

In response, TRAI issued a Consultation Paper on 'Embedded SIM for M2M Communications' on 25.07.2022, inviting comments and counter-comments from stakeholders. 

Fifteen stakeholders provided their input, and an open house discussion on the consultation paper was conducted virtually on 14.12.2022. After thorough analysis of the feedback received and internal deliberations, TRAI has finalized its recommendations.


With the advent of 5G services in India, the M2M ecosystem has witnessed significant expansion, presenting opportunities for applications across various sectors like agriculture, transportation, healthcare, and industrial automation. 

These recommendations aim to streamline the regulatory framework concerning M2M embedded SIM (eSIM) technology in the country. Emphasizing on security, TRAI has highlighted the importance of proper Know Your Customer (KYC) procedures to ensure network security, mitigate fraud risks, and enhance the integrity of the M2M eSIM ecosystem. 

Complementing the eSIM implementation, TRAI has proposed a framework for the switching of eSIM profiles and Subscription Manager-Secure Routing (SM-SR). This framework aims to facilitate greater operational flexibility for M2M eSIM users and promote a competitive landscape within the sector.


The recommendations put forward by the government aim to bolster the growth and development of India's M2M eSIM sector by fostering a conducive environment for domestic players. 

One of the prominent features of these recommendations is the mandatory requirement for the conversion of all communication profiles on M2M eSIMs in imported devices during international roaming in India to profiles of Indian telecom service providers (TSPs) within six months of activation.

Also, specific license holders, including Unified Access Service License holders, Unified License holders, and M2M Service Providers (M2MSPs) with SM-SR management permissions, are granted the authority to own and manage Subscription Manager-Secure Routing (SM-SR) facilities within the country. 


Moreover, OEMs and M2MSPs are provided with the flexibility to choose between profile downloads from the SM-DP of Indian TSPs through either existing foreign SM-SRs or new Indian SM-SRs for the installation of profiles on M2M eSIMs fitted in devices imported to India. 

Integration and switching of SM-SRs must align with GSMA specifications and be completed within specified timeframes upon formal requests from OEMs or M2MSPs. 

However, the use of the 901.XX IMSI series allocated by the International Telecommunication Union (ITU) to Indian entities for providing M2M services in India is not permitted at this stage due to implementation challenges.


The integration of eSIMs in M2M communication is expected to bring significant benefits across various industries. For manufacturing, eSIM-enabled remote monitoring and control of industrial equipment promise to streamline production processes and enhance efficiency. 

Similarly, in logistics and supply chain management, real-time tracking facilitated by eSIM-enabled devices can improve visibility and optimize operations. This concept extends to smart cities, where eSIMs can interconnect various infrastructure components, facilitating data collection and management for efficient urban planning. 

Correspondingly, eSIMs enable remote monitoring and management of critical systems like electricity grids, ensuring reliable energy distribution and timely maintenance.


Despite its potential, the widespread adoption of eSIMs in M2M communication faces several challenges. 

One of the critical aspects is standardization, ensuring compatibility between eSIMs and different network operator platforms to enable seamless operation across the M2M ecosystem. 

Likewise, M2M service providers and businesses may require enhanced technical expertise to effectively manage eSIM profiles and fully leverage the technology's capabilities. 


Strong cybersecurity measures are also crucial to protect eSIM-enabled M2M networks from cyber threats and unauthorized entry.

TRAI's recommendations represent a significant step forward for M2M communication in India. 

By emphasizing innovation, security, and the development of a robust eSIM ecosystem, these recommendations lay the foundation for a connected future across industries. 

As stakeholders collaborate to address challenges and implement strategies, India can emerge as a leader in adopting eSIM technology for M2M communication, driving efficiency and innovation across various sectors.