In May 2025, the Telecom Regulatory Authority of India (TRAI) released a recommendation paper on the “Terms and Conditions for the Assignment of Spectrum for Certain Satellite-Based Commercial Communication Services”. A look at the background, salient features and industry reaction…

Background

The Department of Space released the draft Space-based Communication Policy in 2021 to liberalise space-based communication and enable private entities to offer commercial services. It invited public comments.

Meanwhile, TRAI, via letters in September 2021 and November 2021, sought specific clarifications from the Department of Telecommunications (DoT) regarding the frequency bands available for the satellite communication (satcom) auction, whether spectrum would be assigned exclusively or shared, and the existing assignment and charging mechanisms for satcom.

DoT, in its reply in November 2021, stated that it needed more time to gather the required data. To avoid delaying the 5G roll-out, it advised TRAI to proceed with consultations on all matters except satcom, which could be addressed once the complete data became available. This led to a tempo­rary pause in deliberations on satellite spectrum matters.

Thereafter, in August 2022, DoT provided the requested data and sought TRAI’s recommendations on several new issues. These included evaluating demand for space-based services and suggesting the quantum of spectrum to be auctioned; examining the feasibility of sharing spectrum among multiple service licensees; recommending sharing protocols between satellite and terrestrial networks; and proposing mechanisms for flexible spectrum use to support both satellite and terrestrial applications across user and feeder links.

In October 2022, TRAI sought further clarifications, including the types of licensed services eligible for spectrum through auction. In December 2022, DoT responded, asking TRAI to provide suitable recommendations for each service category after due analysis.

To facilitate stakeholder feedback, TRAI released a consultation paper in April 2023 titled “Assignment of Spectrum for Space-based Communication Services”. An online open house discussion followed in July 2023. Meanwhile, in December 2023, Parliament enacted the Telecommunication Act, 2023, which consolidated laws related to telecom networks, service expansion and spectrum assignment. Following this, in February 2024, TRAI informed DoT that its earlier reference on space spectrum auctions might need to be reviewed under the new legal framework.

In July 2024, DoT sent a fresh reference under Section 11(1)(a) of the TRAI Act, 1997, seeking recommendations on spectrum pricing and assignment conditions for satellite-based commercial services. In another letter the same month, DoT reminded TRAI that its 2021 recommendations to reduce spectrum usage charges from 4 per cent to 1 per cent of adjusted gross revenue for very small aperture terminal closed user group licensees had not been implemented yet, and charges remained at 3-4 per cent. This was to be considered in TRAI’s upcoming response. TRAI then released a second consultation paper in September 2024 titled “Terms and Conditions for Assignment of Spectrum for Certain Satellite-based Commercial Communication Services”.

Key features of TRAI’s new recommend­ations

Based on inputs from 30 stakeholders and 12 counter-comments, TRAI formulated the latest recommendations. Its key features include:

Frequency bands for satellite services

TRAI, in response to industry inputs, examined and recommended appropriate frequency bands for non-geostationary satellite orbit (NGSO)-based fixed satellite services (FSS) and GSO/NGSO-based mobile satellite services (MSS) covering voice, data, text and the internet. As per DoT, NGSO FSS systems mainly use K-under (Ku) and K-above (Ka) bands for user links, with Ka also used for feeder links. Newer systems are deploying higher bands, including the V-band (37.5-52.4 GHz) for user/gateway links and the E-band (71-76/81-86 GHz) for gateway links.

In alignment with the National Frequency Allocation Plan 2022, TRAI recommended that for NGSO-based FSS used in data communication and internet services, the frequency spectrum in the Ku, Ka and Q/V bands should be considered for both user and feeder links. For GSO/NGSO-based MSS providing voice, text, data communication and internet services, the recommended frequency bands are the L-band and S-band for user links, and the C-band, Ku-band, Ka-band and Q/V bands for feeder links.

Are ITU-RR provisions sufficient?

Stakeholders are divided on whether existing International Telecommunication Union (ITU) Radio Regulations (ITU-RR) are adequate for managing interference among the growing number of NGSO satellite systems. While some view the current framework as sufficient, others advocate for additional measures such as band segmentation, angle splitting and defined sharing rules, similar to those implemented by the Federal Communications Commission (FCC) in the US. Concerns were raised about administrative challenges in managing frequency sharing among multiple NGSO operators. Though India is yet to launch space-based NGSO communication services, countries such as the US and UK have successfully coordinated multiple NGSO networks under established regulations. India’s Indian National Space Promotion and Authorisation Centre guidelines already require interference analysis and provide safeguards against harmful interference, including suspension of authorisation. However, measures such as band segmentation may result in inefficient spectrum use.

TRAI recommended that to control interference, the relevant provisions of ITU-RR should be made applicable to the authorised entities as well as other entities that have been authorised by the central government. Further, the ITU framework for coordination among NGSO-based satellite systems, as may be laid down by the ITU in the future, should also be made applicable. It added that the frequency spectrum identified by the government for satellite-based telecommunication services in the higher frequency bands such as C, Ku, Ka and Q/V bands that are assigned on a shared basis should be assigned, with a condition that each authorised entity and all other entities that have been authorised by the central government to use such shared frequency spectrum will coordinate among themselves in good faith. TRAI noted that a provision should be included in the terms and conditions of the assignment of frequency spectrum, stating that if the need arises, the government may prescribe a framework for sharing spectrum in higher frequency bands (such as the C, Ku, Ka and Q/V bands), which will be binding on the authorised entities and all other entities authorised by the central government to use such shared spectrum. Furthermore, the government, with the help of the Telecom Engineering Centre, should examine the need to prescribe a framework for spectrum sharing. This framework may include conditions such as limits on the maximum equivalent power flux density. To encourage satellite operators to coordinate among themselves in good faith at the earliest, the government may also consider introducing a provision for splitting spectrum as a last resort in line with the provision created by the FCC in its “Spectrum Sharing Rules for Non-Geostationary Orbit, Fixed-Satellite Service Systems”, in cases where two or more NGSO-based FSS satellite systems fail to complete coordination.

Another issue under consideration is whether there should be mandated protection or coordination distances between satellite Earth station gateways operating in the same frequency band, specifically between gateways of GSO and NGSO systems, and among different NGSO systems. Stakeholders offered differing views – some argued that no such distances are necessary due to existing safeguards, while others supported defining a “coordination distance.” This would require any new gateway to be set up within a certain distance of an existing one to coordinate operations to avoid harmful interference. GSO gateways, governed by ITU-R Radio Regulations (Article 22), typically use highly directional antennas and are thus less susceptible to interference, allowing for close proximity deployment. However, NGSO gateways use dynamic, tracking antenna arrays, making coordination more complex.

TRAI noted that coordination distances, where required, should be tailored based on the frequency band and technical characteristics of the specific NGSO system. TRAI recommended that, to mitigate the risk of scarcity of gateway sites, satellite Earth station gateways should be installed and commissioned within 12 months from the date on which the central government grants permission to the authorised entities for their establishment.

Timelines for frequency spectrum assignment

The issue pertained to whether fixed timelines should be set for processing frequency spectrum applications for NGSO-based FSS and GSO/NGSO-based MSS. Stakeholders widely supported defining such timelines to expedite service deployment. They suggested that once an entity receives in-principle approval from the central government, the spectrum should be assigned within a specific period.

Agreeing with this, TRAI recommended that there should be a defined timeline, not exceeding 30 days from the date of application, within which the frequency spectrum should be assigned to an authorised entity for the provision of satellite-based communication services, provided that the in-principle clearance of satellite network has been given by the central government. In the case of an objection, the same may be communicated to the concerned authorised entity within a window of 30 days from the date of application for necessary action.

Spectrum charging for NGSO-based FSS and GSO/NGSO-based MSS

Stakeholders expressed varied views on spectrum charging. Most supported charging a percentage of the adjusted gross revenue (AGR), citing its fairness, transparency and ability to align costs with operator earnings. AGR-based charges promote investment and innovation, particularly benefiting smaller operators by reflecting the shared nature of satellite spectrum use. Some suggested a per MHz approach for simplicity and efficiency, while others proposed aligning satellite charges with terrestrial spectrum pricing to maintain a level playing field. A few stakeholders also recommended differentiated or waived charges for rural or government-backed satellite services to promote broader connectivity.

To this, TRAI recommended that spectrum charges for NGSO-based FSS should be levied at 4 per cent of the AGR. Meanwhile, NGSO-based FSS providers should also pay an additional per subscriber charge of Rs 500 per annum in urban areas, while exempting the rural and remote areas from this additional charge.

Industry reactions

Telecom operators, represented by Cellular Operators Association of India, reportedly plan to contest TRAI’s recommendation of AGR-based administrative pricing for satellite spectrum. Telcos argued that satellite services compete in urban areas, where deployment is permitted, thus negating the complementary-use rationale. They asserted that allowing satellite providers to operate in overlapping markets without similar financial obligations (such as auctions and revenue-sharing) will create regulatory disparity and undermine competitive neutrality.

In contrast, the Indian Space Association (ISpA) welcomed TRAI’s approach, stating that administrative allocation promotes spectrum sharing, competition and efficient utilisation. ISpA highlighted that this model is vital for expanding India’s satcom ecosystem and bridging the digital divide.

Harshita Kalra