As of December 2024, 29 entities have been granted the mandatory No Objection Certificate (NOC) to sell international SIMs and global calling cards to Indian travelers heading abroad. This development is part of the Telecom Regulatory Authority of India’s (TRAI) ongoing efforts to shape a regulatory framework for the sale of foreign telecom service providers’ SIM ‘s and eSIM ‘s—particularly those embedded in M2M (machine-to-machine) and IoT (Internet of Things) devices intended for export. eSIM regulation India

TRAI is now seeking stakeholder feedback on whether a new category of service authorization is needed for these foreign SIMs/eSIMs. It is also examining the Know Your Customer (KYC) requirements for users, and exploring whether other agencies such as the Reserve Bank of India (RBI) or customs departments should have a role in regulating the import and use of these SIMs/eSIMs in exported products.

This consultation gains urgency in light of recent enforcement actions: in January 2024, the Department of Telecommunications (DoT) ordered the removal of global eSIM providers like Airalo and Holafly from the Google Play Store for failing to secure the necessary NOC. While TRAI’s current consultation is focused on M2M/IoT use cases, it signals a broader policy shift toward tightening control over foreign SIM and eSIM services in India.

Selling International SIMs in India? Here’s What the 2022 DoT Terms Demand

In January 2022, the DoT released revised terms and conditions for foreign operators to sell and rent international roaming SIMs in India. These terms require foreign operators to verify customer authenticity using measures like collecting a copy of the customer’s passport, a valid visa, and additional proof of identity (PoI) and proof of address (PoA), or through an alternate process that the DoT may prescribe for digital KYC.

In countries where Indian citizens do not need a visa, the operators must collect a copy of a valid travel ticket, along with an undertaking from the customer stating the country/places they intend to visit. These foreign SIMs can only be used outside India.

Foreign operators have to submit a monthly report to security agencies, including complete details of such global cards (including the period), along with full particulars, including the address of the person to whom the international roaming cards have been sold/rented. As per the 2022 policy, the DoT decides to approve innovative application-based solutions on a case-by-case basis. The government can ask the company providing an app-based SIM solution to give a presentation of their solution or provide information as necessary. A decision from the DoT on such matters is final and binding.

The NOC is valid for three years, and the holder is expected to obtain all required clearances from concerned authorities such as the RBI, customs, etc. The DoT can suspend the NOC before its expiration if it deems it necessary in the interest of state security or for the proper conduct of the telegraph. The NOC holder must also provide Indian customers with a grievance redressal mechanism on par with what Indian companies offer.

TRAI Proposes 10-Year License for Foreign SIMs

In June 2024, the Department of Telecommunications (DoT) requested recommendations from TRAI regarding the terms and conditions for granting service authorizations under the Telecom Act, 2023. In its response, TRAI proposed the introduction of a specific service authorization for the sale and rental of international roaming SIM cards and global calling cards provided by foreign operators. This authorization would adopt a light-touch regulatory approach and be valid for a period of ten years.

TRAI recommended that the government and its authorized agencies retain the right to inspect any premises or offices used by foreign providers for delivering SIM services. Additionally, the authorization could be suspended if deemed necessary by the authorities. While a 60-day notice period would typically be required for revocation, the Central Government would have the power to suspend or revoke the authorization without notice in situations involving national security, emergencies, war, or low-intensity conflict.

The proposed framework would also empower the DoT to revise or add new conditions to the authorization if it considers such changes essential for national security, public interest, or the effective management of telecommunications. The DoT has accepted TRAI’s recommendations in principle and has suggested that this authorization process should be consistent with other existing service authorizations.

Indian IoT Makers Need Foreign eSIMs—But Existing Rules May Not Fit, Says DoT

In reference to the regulator dated September 2024, the DoT mentioned that certain Indian M2M and IoT device manufacturers want to export their products to the international market. These manufacturers were looking for foreign SIMs that could be integrated into their products for sale outside of India. eSIM regulation India

So far, the DoT has received requests for an NOC for such services under its 2022 NOC policy for the sale and rent of international roaming SIMs/global calling cards from foreign service providers. The DoT believes there are practical challenges in applying the existing regulations to foreign eSIMs for M2M and IoT products, especially in the context of Know Your Customer (KYC) and other compliance requirements. While the DoT had conducted a consultation on the subject in 2022, only two entities responded.

Industry Seeks Green Light for Foreign eSIMs in India’s Growing IoT Ecosystem

Out of the two responses the DoT received during its 2022 consultation, TRAI’s current paper includes only the submission from the Confederation of Indian Industry (CII). In its response, CII emphasized that the industry supports allowing the sale of foreign SIMs, as well as their use in IoT and M2M applications—provided these SIMs are only activated outside India.

In addition to the IoT/M2M aspect, CII also advocated for permitting the availability of foreign eSIMs within India. The organization noted the rising demand for eSIMs driven by the growing number of compatible devices and use cases. CII called for easing regulatory norms, particularly given the challenges posed by the pandemic at the time of the consultation.

Final thoughts about eSIM regulation India

India’s evolving stance on foreign SIMs and eSIMs reflects a broader global tension between enabling seamless global connectivity and ensuring national regulatory oversight. While TRAI’s current consultation is framed around M2M and IoT applications for export, its implications go much further—potentially shaping how foreign eSIM providers operate in one of the world’s fastest-growing digital markets.

Globally, we’ve seen contrasting approaches. The EU, for instance, has embraced eSIMs with minimal barriers, aligning with its Digital Single Market goals and fostering competition across borders. Meanwhile, China has adopted a highly controlled approach, limiting foreign eSIM integrations and ensuring tight regulatory oversight on all connectivity entering or leaving its borders. The U.S. sits somewhere in the middle—encouraging innovation and device-driven adoption, but still grappling with fragmented carrier compliance and data sovereignty concerns. eSIM regulation India

India’s direction seems to be converging toward a hybrid model: open to global players but within a tightly regulated framework. This “light-touch authorization” TRAI proposes mirrors strategies adopted in places like Singapore, where regulatory flexibility is paired with strong compliance expectations.

Looking ahead, the pressure to regulate foreign eSIMs will only intensify. As more devices—from smartwatches to export-bound IoT sensors—rely on eSIMs for instant global connectivity, regulators will be forced to adapt. The next few years may see a global push for mutual recognition of eSIM authorizations, akin to international roaming agreements, especially as satellite-based connectivity and borderless IoT networks blur traditional telecom boundaries.

For eSIM providers, India will remain a challenging but essential market. Those who can navigate its regulatory maze—offering compliant, secure, and transparent services—will find strong demand among travelers, exporters, and digital businesses alike. For India, the key will be striking a balance between security, innovation, and global competitiveness in the connectivity space.