The Telecom Regulatory Authority of India (TRAI) has released recommendations on the use of embedded SIMs for M2M communications.

With the rolling out of 5G services in the country, the opportunities for the M2M ecosystem have increased scope for applications in various sectors of the economy such as agriculture, transportation, healthcare and industrial automation. These recommendations are aimed at streamlining the regulatory landscape of M2M embedded SIM (eSIM) in India.

Through these recommendations, the authority is emphasising network security, mitigating fraud risks and enhancing the overall integrity of the M2M eSIM ecosystem. The authority has also recommended a framework for profile switching of eSIMs. This will provide flexibility to the M2M eSIM users and should promote healthy competition in the sector.

Implementation of these recommendations by the government should promote orderly growth in the M2M eSIM segment of the telecom sector in India and stimulate the development of a homegrown M2M eSIM ecosystem in the country, thus enabling the growth of modern M2M communication.

The recommendations say all communication profiles on any M2M eSIM fitted in an imported device on international roaming in India should be mandatorily converted or reconfigured into communication profiles of Indian telecom service providers (TSPs) within six months from the date of activation of international roaming on such M2M eSIM or on change of ownership of the device, whichever is earlier.

Licence holders and companies holding M2M service provider registration with permission to own and manage subscription manager and secure routing (SM-SR) in India should be permitted to own and manage SM-SRs in the country.

For installation of profiles of Indian TSPs on M2M eSIMs fitted in the devices imported in India, the concerned OEM and M2M service provider should be given the flexibility to choose between profile download from the subscription manager data preparation (SM-DP) of the Indian TSP to the M2M eSIMs through the existing (foreign) SM-SR or profile download from the SM-DP of the Indian TSP to the M2M eSIMs through the new (Indian) SM-SR, after the SM-SR switch from foreign to Indian.

The M2M service provider registrant or telecommunication service licensee, whose SM-SR controls M2M eSIMs in India, should not refuse integration of its SM-SR with the SM-DP of the licensed telecom service provider, whose profiles are to be added in such M2M eSIMs on the request of the concerned OEM or M2M service provider. The integration of SM-SR with SM-DP should be carried out in accordance to the GSMA’s specifications and should be completed within three months from the date of receipt of the formal request from the concerned OEM or service provider.

The M2M service provider registrant or telecommunication service licensee should also mandatorily facilitate switching of its SM-SR with the SM-SR of another entity, eligible to hold SM-SR in India, upon the request of the concerned OEM or M2M service provider. Such SM-SR switching should be carried out as per the GSMA’s specifications and should be completed within six months from the date of receipt of a formal request from the concerned OEM or M2M service provider.

Keeping in view the challenges in its implementation, the use of 901.XX IMSI series allocated by International Telecommunication Union to Indian entities should not be permitted for providing M2M services in India at this stage.

The recommendations follow the Indian Department of Telecommunications (DoT) in 2021 seeking TRAI’s embedded SIM usage. TRAI thus issued a consultation paper in 2022 for soliciting comments and counter comments from stakeholders; 15 stakeholders submitted their comments.

An open house virtual discussion on the consultation paper was held in December 2022. Based on the comments and inputs received from stakeholders, deliberations on the subject and on its own analysis, TRAI has now finalised its recommendations.

The recommendations have been placed on TRAI’s web site at www.trai.gov.in/sites/default/files/Recommendations_21032024_0.pdf.