On 4th July 2025, the Telecom Regulatory Authority of India (TRAI) released a much-anticipated Consultation Paper on the regulatory framework for the sale of foreign telecom service providers’ SIM/eSIM cards for use in M2M/IoT devices meant for export purposes. This move is poised to bring transformative regulatory clarity and operational ease to Indian manufacturers engaged in exporting connected products embedded with foreign network SIMs or eSIMs.
📡 The Evolving Telecom Landscape and M2M/IoT Export
India’s ambition to emerge as a global manufacturing and export hub for smart devices is tightly linked to advancements in Machine-to-Machine (M2M) and Internet of Things (IoT) technologies. M2M devices like smart meters, connected cars, and industrial sensors often require cellular connectivity outside India, especially when exported.
To support this use case, manufacturers need access to foreign SIMs or eSIMs (already configured with foreign operator profiles) for embedding into products at the time of manufacturing. However, India’s current regulatory framework—built primarily for personal SIM usage or international roaming—has not adequately addressed this specialized requirement.
📜 Why This Consultation Paper Matters
The Department of Telecommunications (DoT), through its letter dated 17 September 2024, sought TRAI’s recommendations on issuing or renewing No Objection Certificates (NOCs) for importing/selling foreign SIMs or eSIMs in India specifically for use in export-only M2M/IoT devices. TRAI’s response to this request forms the basis of the new consultation paper.
The existing 2022 NOC policy only permits entities to sell/rent international roaming SIMs or global calling cards for Indian customers traveling abroad. It does not account for the practical realities faced by IoT manufacturers needing to integrate foreign SIMs into devices being exported—creating hurdles around KYC, SIM activation, and compliance.
🔍 What TRAI Is Exploring
This consultation paper invites stakeholder views on several key questions, such as:
Should a separate NOC policy be created for the sale of foreign SIMs for export-only IoT/M2M use?
What should be the KYC and compliance requirements, if the device is not to be used domestically?
How can security, traceability, and misuse be prevented without overburdening exporters?
Notably, TRAI recognizes the distinct technical and commercial requirements of M2M communications—where devices function autonomously, often across borders, without direct human interaction.
🗣 Stakeholder Participation Invited
TRAI has invited written comments from stakeholders by 1st August 2025, and counter-comments by 18th August 2025. Inputs should be sent electronically to:
Shri Akhilesh Kumar Trivedi, Advisor (Networks, Spectrum and Licensing), TRAI
📧 advmn@trai.gov.in
📞 +91-11-20907758
All submissions will be published on the TRAI website to ensure transparency and encourage informed debate.
🛠️ Why This Is a Step in the Right Direction
This consultation marks a critical step in liberalizing and modernizing telecom regulations in India to match global industry trends. By allowing the regulated integration of foreign SIM/eSIMs into export-oriented products, India can better support:
IoT hardware startups and exporters
OEMs and M2M solution providers
Automotive and electronics sectors, especially those manufacturing for global markets
It also ensures that national security, traceability, and spectrum policies remain intact, while removing unnecessary bottlenecks.
🔚 Final Thoughts
TRAI’s move to seek stakeholder inputs for framing a dedicated policy around foreign SIM/eSIM usage in M2M export devices is timely and essential. As India scales up its “Make in India for the World” strategy, creating an enabling regulatory environment for IoT exports is a prerequisite for success.
Stakeholders—especially manufacturers, IoT platform providers, telecom operators, and global SIM vendors—should seize this opportunity to help shape a forward-looking and balanced policy.