Machine-to-machine (M2M) communication is a form of data exchange that involves one or more entities communicating without human intervention. When devices connect via the internet, they become part of the internet of things (IoT) system. The M2M ecosystem is distinct from the standard telecommunications ecosystem, being more diverse and involving multiple stakeholders.
In October 2023, the Telecommunication Engineering Centre defined M2M as technologies that allow wired and wireless systems to communicate with similar devices. M2M employs devices such as sensors and meters to capture events such as motion, meter readings and temperature, which are then relayed through a network (wireless, wired or hybrid) to an application that translates these events into meaningful information.
This connectivity enables governments, businesses and individuals to digitalise the physical world into seamless interactions. From enhancing the resilience of services such as healthcare, energy distribution and transportation to optimising sectors such as retail, agriculture and smart homes, IoT and M2M have the potential to transcend traditional boundaries and redefine how we live, work and interact with our environment. M2M can enable a wide range of applications and services across various vertical markets, including automotive, utilities, healthcare, safety and surveillance and public safety. The M2M ecosystem includes a wide array of diverse players deploying innovative services across different networks, technologies and devices. Therefore, clear and consistent regulations for equivalent services and policies that promote growth are crucial to fully leverage the opportunities in this market.
In this context, the Telecom Regulatory Authority of India (TRAI) released a consultation paper on the issues related to critical sectors in M2M communication and the transfer of ownership of M2M SIMs. This paper is a response to a request from the Department of Telecommunications (DoT) to reconsider TRAI’s 2017 recommendations, which mandated that critical M2M and IoT services be provided only by connectivity providers using licensed spectrum.
Background
In May 2015, DoT published the National Telecom M2M Roadmap, outlining the policy and regulatory approach to support the M2M ecosystem in India. Consequently, in September 2017, TRAI recommended that DoT identify critical M2M services and mandate their provision by connectivity providers using licensed spectrum. The government accepted this recommendation, and in November 2019, the Inter-Ministerial Working Group was formed to gain a comprehensive understanding of critical M2M applications. The Group’s report, released in March 2021, identified 20 critical M2M services.
Following the report, DoT consulted with stakeholders, revealing several key points. Stakeholders argued that mandatory use of licensed spectrum for critical M2M services is unnecessary if service level agreements and quality of service (QoS) requirements can be met with unlicensed spectrum. They suggested that enforcing the provision of critical services exclusively through licensed bands and licensed telcos could hinder market growth. Meanwhile, stakeholders also emphasised that the security of M2M devices does not depend on whether the spectrum is licensed or unlicensed.
It was also mentioned that incorporating M2M/IoT devices under the trusted source/trusted product regulation could enhance the security of critical infrastructure sectors more effectively than merely mandating service provision by licensed connectivity providers.
Current framework for M2M services
DoT has established a three-tier regulatory framework for M2M communication services in the country. Under the current framework, entities with “M2M authorisation under a unified licence (UL)” are permitted to provide M2M communication services using low power wide area network or similar technologies over unlicensed spectrum. Additionally, entities holding access service authorisation under the UL and unified access service licence can acquire licensed access spectrum from DoT to offer wireless access services, including M2M communication services. This structured approach aims to facilitate the growth and efficiency of M2M communication across the nation.
Issues for consultation in the M2M sector
TRAI has released a consultation paper highlighting issues related to critical services in the M2M sector. The authority has raised several key concerns. First, it questions whether there is a need for a comprehensive guiding framework to define a service as a critical M2M/IoT service and what such a framework should entail. Second, it considers whether critical services in the M2M sector should be allowed to use unlicensed spectrum in addition to licensed spectrum. Last, TRAI is examining whether M2M devices should be brought under the trusted source/trusted product framework, and if so, which devices should be included. This framework mandates that telecom companies procure telecom equipment only from vendors listed as trusted sources by the National Cyber Security Coordinator.
Transfer of ownership of M2M SIMs
SIMs are essential for providing telecommunication services using 3rd Generation Partnership Project standards. These SIMs contain communication profiles that uniquely identify cellular mobile subscriptions. In the context of M2M mobile communication, these SIMs are known as M2M SIMs.
On January 1, 2024, DoT referenced an industry request to allow the transfer of ownership of M2M SIMs in various scenarios. These include the involvement of mergers, acquisitions, company takeovers and situations where companies want to transfer ownership between parent companies and their subsidiaries or other group companies. This also applies to cases where M2M service providers (M2MSPs) are ceasing operations or filing for bankruptcy, necessitating the transfer of M2M SIMs either to a new M2MSP or directly to the company where the M2M SIMs are deployed.
Need for regulatory framework in M2M SIMs
The current regulatory framework for changing the ownership of SIMs in the country includes specific guidelines—for consumer connections, SIM ownership changes are permitted only between blood relatives and legal heirs. However, for M2M connections, there is no provision for changing the ownership of M2M SIMs.
The entities holding M2MSP registrations may undergo mergers, acquisitions, business closures or reorganisations within their business groups. In such situations, it is essential to ensure that subscribers are not inconvenienced and that M2M services remain seamlessly available. This underscores the need for a regulatory framework that facilitates the transfer of ownership of M2M SIMs, thereby preventing service disruptions and inconvenience to users.
To this end, TRAI has raised several issues that need to be addressed. First, there is a need to establish a regulatory framework for the transfer of M2M SIM ownership among M2MSPs. Stakeholders are asked to suggest the salient features of such a framework and identify scenarios in which ownership transfers should be permitted. Second, stakeholders should provide recommendations on measures to prevent the misuse of this facility and consider what flexibility should be given to the new M2MSP for maintaining connectivity for existing customers. This comprehensive input will help in forming a robust framework that ensures continuity and reliability in M2M services while accommodating the necessary business changes.
The way forward
Going forward, M2M communication is poised to permeate all aspects of human life over the next 10-15 years, becoming a transformative force for industry and the broader economy. Therefore, it is crucial to establish a timely policy framework to promote this technology and ensure that its full benefits reach citizens. However, despite the vast market opportunities for IoT and M2M, adoption has fallen short of expectations, especially in developing countries. Several stakeholders have suggested a balanced approach, utilising both licensed and unlicensed bands, to enhance the customer experience and drive innovation. This approach will also make these technologies more affordable and accessible.
In 2023, the global M2M market, valued at $21.2 billion, contributed less than 1 per cent to the global telecommunications market, which stood at $2,970.7 billion. To achieve technological ubiquity for IoT and M2M, significant efforts are still needed from IoT ecosystem stakeholders, governments and regulators.
Niha
