The Telecom Regulatory Authority of India (TRAI) has released Recommendations on ‘Usage of Embedded SIM (eSIM) for Machine-to-Machine (M2M) Communications’.
The Department of Telecommunications (DoT), through its letter dated November 9, 2021, sought TRAI’s recommendations on the usage of eSIM for M2M communications. In this regard, TRAI issued a consultation paper on ‘eSIM for M2M Communications’ on July 25, 2022, to solicit comments/counter comments from stakeholders. In response, 15 stakeholders submitted their comments. An open house discussion on the consultation paper was held on December 14, 2022, through virtual mode. Based on the inputs received from stakeholders, extensive deliberations on the subject and its own analysis, TRAI has finalised its recommendations on the usage of eSIM for M2M communications.
According to TRAI, with the rolling out of 5G services in the country, the opportunities for the M2M ecosystem have expanded greatly, offering 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 eSIM in India. Through these recommendations, the regulator has laid emphasis on ensuring security by way of proper know your customer (KYC), which is essential for ensuring network security, mitigating fraud risks, and enhancing the overall integrity of the M2M eSIM ecosystem. TRAI has also recommended a framework for profile switching of eSIMs and swapping of subscription manager-secure routing (SM-SR). This will provide significant flexibility to the M2M eSIM users and will promote healthy competition in the sector.
As per the recommendations, for installation of profiles of Indian telecom service providers (TSPs) on M2M eSIMs fitted in the devices imported in India, the concerned original equipment manufacturer (OEM) and M2MSP should be given the flexibility to choose between profile downloads 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 SM-SR, after SM-SR switch from foreign to Indian. The M2MSP registrant/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 TSP, whose profiles are to be added in such M2M eSIMs, upon the request of the concerned OEM/M2MSP. The integration of SM-SR with SM-DP should be carried out in accordance with the GSMA’s specifications and should be completed within a period of three months from the date of receipt of the formal request from the concerned OEM/M2MSP.
Further, TRAI recommends that the M2MSP registrant/telecommunication service licensee, whose SM-SR controls M2M eSIMs in India, should mandatorily facilitate the 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/M2MSP. Such SM-SR switching should be carried out as per the GSMA’s specifications and should be completed within a period of six months from the date of receipt of the formal request from the concerned OEM/M2MSP. Keeping in view the challenges in its implementation, the use of 901.XX Global International Mobile Subscriber Identity (IMSI) series allocated by the International Telecommunication Union (ITU) to Indian entities should not be permitted to provide M2M services in India, at this stage.
