The Telecom Regulatory Authority of India (TRAI) has recently floated a consultation paper to review the existing regulations around international roaming in order to protect subscribers from bill shocks during mobile phone usage in foreign countries. When a phone bill includes unexpected charges, it evokes a shock among subscribers. The international mobile roaming (IMR) service implies a de facto monopoly of the home operator, which raises concerns over potential consumer abuse in the form of exorbitant tariffs or a general lack of transparency in the communication of tariffs, leading to a situation of bill shocks.

TRAI’s consultation exercise is focused on identifying specific causes of bill shocks to consumers that avail of the IMR service, assessing the extant regulatory framework for adequacy to deal with the issue, evaluating the range of voluntary policies and measures adopted by telecom service providers (TSPs) in India to prevent instances of bill shocks, and understanding the need for any revision or suitable changes in the regulatory framework.

Extant regulatory framework in India

The extant regulatory framework in India does not provide for price regulation of IMR services. TRAI has followed and expanded the scope of the forbearance regime over the years, and has given service providers the freedom to design tariffs for most of the telecom products, including IMR services, in line with the prevailing market conditions.

As regards the protection of consumer interests, TRAI has mandated that a service provider must immediately alert customers (with IMR facility on their mobile connection) when they roam outside the territory of India. The alerts can be in the form of an SMS or USSD, advising consumers to deactivate their data services if they do not intend to use data services while roaming outside the country.

That said, TRAI has observed that the existing regulatory framework is not sufficient to address the issues relating to the provision of IMR service. Therefore, it has decided to review the entire process of provisioning of IMR service to identify issues requiring regulatory intervention and take appropriate action.

Issues for consultation

Activation of international roaming

Currently, there is no standard approach for the activation of international roaming by Indian service providers. Some provide pre-activated international roaming service to prepaid subscribers, but require post-paid subscribers to activate international roaming themselves. Meanwhile, some require both post-paid and prepaid subscribers to activate international roaming themselves. The policies also vary by the licensed service areas and destination countries.

From a subscriber’s point of view, the knowledge of the exact status of the activation of international roaming is critical. There may be subscribers who may be unaware of pre-activation or automatic activation of IMR service, and may unintentionally and inadvertently use voice/data/ SMS services when in international territories, thereby facing major bill shocks. With the automatic activation of roaming services, the data usage in the background by installed applications will continue even if a user is not using the phone actively. This will reflect in data bills.

Thus, it is important for TSPs to either standardise their approach or strengthen the communication process with customers. To this end, TRAI has sought industry views on whether the IMR service should remain inactive at the time of issue of a new SIM and be activated by the subscriber when required. Further, it has invited comments on how and when should the details of activation and applicable tariff be communicated to the subscriber should the service remain inactive at the time of issue of a new SIM.

Tariff offerings and selection of applicable tariff

Regardless of automatic/pre-activation or requested activation of IMR service, the evaluation of tariff offerings and selection of a suitable tariff plan is an important next step from a consumer’s perspective. Currently, most of the service providers are offering tariffs in the form of standard rates and international roaming (IR) packs. If standard rates are adopted, service providers charge based on actual usage, whereas IR packages offer limited usage at predefined rates.

As per TRAI, “Intuitively, standard rates might be relevant for a user with less usage. However, even a cursory glance at tariff offerings of all the TSPs shows that standard rates are significantly higher than the rates offered under the IR packs. Illustratively, an incoming call while roaming in the US is charged at as high as Rs 90 per minute and calls to India from the US at Rs 180 per minute, while one-day IR packs come with unlimited incoming calls and 100 minutes of outgoing calls to India at Rs 575.”

That said, IR packs suffer from rigidity in terms of time period. The widespread trend is to offer such packs for one day, seven days and 30 days, and resultantly, consumers desirous of availing of IMR service for a different period must bear the disproportionate burden.

Given the huge disparity between standard rates and IR packs, TRAI has sought industry views on how these differences can be rationalised. Further, to address the rigidity in chargeable days for IR packs, should TSPs be mandated to permit a combination of different IR plans as per the requirement of the consumer? TRAI has also asked for views on whether IMR tariffs should be calculated in a 24-hour format from the first use of data. This will allow consumers to be charged for making or receiving a call or sending a text message only for those 24 hours in which the services have been used rather than on a calendar day basis.

Other consumer protection measures

Another key area of consideration is the provision of information to consumers regarding the exhaustion of plan benefits. For instance, the review of the terms and conditions imposed by a TSP revealed that usage can be tracked by consumers on their app in real time, but voice/SMS usage updates can be delayed by 24-48 hours. It is observed that if data usage can be tracked in real time, it may also be technologically feasible that SMS alerts can be sent to the consumer when the data usage exceeds certain levels such as 50 per cent, 80 per cent, 90 per cent and 100 per cent of the data entitlement. As regards voice and SMS usage, it is important that the delay is as less as possible and international best practices should be adopted in this regard.

To this end, TRAI has sought views of the stakeholders on whether it should be mandated for service providers to send updates when data usage exceeds certain pre-established milestones.


Mobile tariffs are generally complex due to the multiplicity of components and associated terms and conditions, and inevitably create a possibility of bill shock if there is a lack of transparency in the communication of tariffs by the TSP or a lack of understanding on the part of the consumer or a combination of both.

Interestingly, the concerns relating to abusive tariffs and bill shocks are universal and have received a lot of attention not only from various national regulatory agencies but also from organisations such as the ITU, OECD and GSMA. The International Mobile Roaming Strategic Guidelines published by the ITU in 2017 list price regulation consumer protection among the key IMR regulatory issues. Despite some limitations on price regulation of IMR service, it appears that price regulation targeting IMR retail prices is being practised in many countries across the world, particularly in Europe, Africa, the Asia-Pacific and the Arab region.

That said, consumer empowerment by enhancing the availability of information has been the preferred approach for most of the national regulatory agencies. TRAI’s present consultation paper is timely and will go a long way in establishing best practices to avoid instances of bill shocks in the Indian context.

By Akanksha Mahajan Marwah