TRAI recommendations for M2M IoT service guidelines

IoT SIM Card
TRAI (Telecom Regulatory Authority of India) has released its recommendations on spectrum, roaming and QoS related requirements in machine-to-machine (M2M) communications.

IoT projects in India

# 100 smart city projects
# 14 smart grid pilots
# Commercial passenger vehicles with GPS, emergency calls etc.

India Government, as per a draft policy on Internet of Things – 2015, aims to create an IoT industry in India of $15 billion by 2020. This will lead to increase in the connected devices from around 200 million to over 2.7 billion by 2020.

The revenue generated from IoT industry would be $300 billion and the connected devices would be 27 billion by 2020 globally, according to Gartner.

Top 5 fast growing countries with investment opportunities in M2M technology during 2017 – 2022 are China, India and Australia in the Asia Pacific region and Spain and Brazil in the Latin America region, according to Research and Markets.

The lack of industry standards, high amount of initial investment, the lack of technical skills needed for the usage of the technology are some of the limitations of M2M technology. With the advent of 4G and 5G, the M2M technology sees immense opportunities in application in more industries and the evolution of the cloud technology.

M2M recommendations from TRAI

TRAI recommendations for M2M services said all telecom service providers’ viz. CMTS, UASL, UL (AS) and UL holders using licensed spectrum will be allowed to provide M2M connectivity within the area of their existing authorizations. DoT may amend the license conditions in licenses.

All Basic Services licensees and ISP licensees will be allowed to provide M2M connectivity, including on unlicensed band, within the area of their existing authorizations, barring M2M cellular services. DoT may amend the license conditions under Basic Service Operators (BSOs) and respective ISP categories.

All UL (VNO) holders will be allowed to provide M2M connectivity as authorized in their existing authorizations. DoT may amend the license conditions of UL (VNO).

Connectivity provider using WPAN/WLAN technologies for providing M2M for commercial purposes, operating in unlicensed spectrum, should register with DoT.

Connectivity provider using LPWAN technologies operating in unlicensed spectrum should be covered under licensing through a new authorization under UL namely UL (M2M). Such licensees should be allowed to bid for licensed spectrum to provide exclusively M2M services, if they desire to provide M2M services in the licensed band.

UL (M2M) authorization shall comprise of three categories i.e. UL (M2M) Category-A-National area, UL (M2M) Category-B -Telecom Circle/Metro area, UL (M2M) Category –C- SSA/ District area.

Government, through DoT, should identify critical services in M2M sector and these services should be mandated to be provided only by connectivity providers using licensed spectrum.

TRAI, Central Drug Standards Control Organization, National Highways Authority of India, Inland Waterways Authority of India, Central Electricity Regulatory Commission, etc. and Ministry of Law & Justice should be members in M2M apex body formed by DoT.

M2M Service Providers (MSPs) should register as M2M service provider as envisaged by DoT. This registration will be exclusive for the MSP and not part of existing OSP registration. Exclusive guidelines for MSP Registration should be issued. MSPs need to provide details of the connectivity provider who would be providing connectivity in their M2M application.

Device manufacturers should be mandated to implement “Security by design” principle in M2M device manufacturing so that end-toend encryption can be achieved.

The government should provide comprehensive guidelines for manufacturing/ importing of M2M devices in India.

A National Trust Centre (NTC), under the aegis of TEC, should be created for the certification of M2M devices and applications (hardware and software).

For connectivity provider using technologies in WPAN/WLAN operating in unlicensed band, there should not be any Performance Bank Guarantee (PBG) or Financial Bank Guarantee (FBG). A nominal 130 fee maybe charged to cover administrative cost.

For obtaining authorizations under UL (M2M) Category ‘A’ for National area, UL (M2M) Category ‘B’ for Telecom circle/ Metro area and UL (M2M) Category ‘C’ for SSA area, the amount payable in the form of Entry Fee, PBG, FBG shall be as per the table below.

As regard to the case of MSP, the Entry Fee, Performance Bank Guarantee (PBG) or Financial Bank Guarantee (FBG) should be same as envisaged by DoT in “M2M Service Providers Registration –Draft Guidelines May 2016”

Spectrum allocation should be technology and service neutral. No separate spectrum band is to be allocated exclusively for M2M services.

Requirement of additional licensed spectrum for access services to meet the projected influx of connected devices due to M2M communication will be revisited by the Authority after WRC-19.

In order to facilitate smooth roll out of M2M services utilizing the license exempt spectrum, 1 MHz of spectrum from 867-868 MHz and a chunk of 6 MHz of spectrum at 915-935 MHz is recommended to be delicensed.

TRAI on various occasions has recommended to the Government for delicensing the V-band (57-64 GHz). This may be done on priority.

National roaming for M2M/ IoT shall be under forbearance and ceiling as per prevailing Telecom Tariff Orders (TTOs) for access service.

TSPs shall enter into commercial agreements to cater their roaming requirements for M2M subscribers.

TRAI shall review/issue separate TTO for M2M at an appropriate time in future, if deemed fit.

As a part of public safety initiative, the Government shall initiate a proof-of-concept (PoC)/ Pilot testing in integrating the emergency response service on the lines of eCall to make suitable mandatory provisions for emergency communication in vehicles.

Devices with pre-fitted eUICC should be allowed to be imported only if it has the ability to get reconfigured ‘Over the air’ (OTA) with local subscription. GSMA approved guidelines shall be followed for provisioning of new profile remotely with ‘Over-the-air’ (OTA) mechanism.

Devices fitted with eUICC shall be allowed in operation in roaming for maximum three years from the date of activation of roaming in the network of Indian TSP and mandatorily converted/ reconfigured into Indian TSP’s SIM within the stipulated period or on change of ownership of the device, whichever is earlier.

Country specific relaxation on permanent roaming of foreign SIMs, if any, can be considered based on the strategic importance, Bilateral or Multi-lateral trade agreements and principle of reciprocity by the government.

In case imported equipment to which the SIM/ device is fitted with such as automobile/ machines (like earth movers), arms etc. (requiring mandatory registration at local authorities such as RTO, State/ District administration) is transferred/ sold to another party before three years, the roaming device (eUICC) shall also be immediately configured with local subscription/eUICC of Indian TSP.

It should not be mandatory to use only domestically manufactured SIMs in M2M. Embedded SIMs with standard specifications can be imported and relevant information shall be submitted by importer while import of the devices/SIMs.

Suitable security mechanism similar to the existing mobile networks shall be put in place by the DoT for the Border States like J&K and NE areas, if deemed fit.

There is no case for regulatory intervention for setting ceiling for roaming charges for the devices imported with in-built SIM. The market forces shall address the issue based on commercial aspects.

International roaming in M2M shall be allowed under the well recognized framework of GSMA ‘M2M Annex’ to keep uniformity of the parameters and processes.

In order to boost the M2M/IoT manufacturing in India, the government may consider feasibility of allowing extra-terrestrial usage of IMSI ranges with suitable framework on the basis of country specific bilateral agreements.

Allocation of various network codes including MNCs shall be to licensed TSPs only.

There is no need to allocate MNCs or any other network codes to MSPs.

Once the M2M sector develops, the Authority will put in place comprehensive regulations on QoS parameters in M2M communication, as per service requirements.

In the present stage of deployment of M2M devices and services, a duty cycle of 10 percent both at device level and network level would suffice to meet the requirements. These parameters can be reviewed once there is substantial deployment of M2M ecosystem in the country and sufficient data being made available for analysis of use cases.

After due deliberation, TRAI will issue comprehensive recommendations on Data Protection for M2M customers in India.