New Delhi (ABC Live): TRAI’s Foreign M2M SIM Framework: India’s ambition to become a global manufacturing hub for connected devices is accelerating. Today, products such as smart electricity meters, industrial sensors, connected vehicles, and farm automation tools form a growing share of India’s export basket. At the same time, these products rely on one common element: connectivity.

However, connectivity is no longer a passive component. Instead, it defines who controls a device, where its data flows, and which laws apply.

Against this backdrop, on 30 December 2025, the Telecom Regulatory Authority of India (TRAI) issued recommendations titled “Regulatory Framework for the Sale of Foreign Telecom Service Providers’ SIM/eSIM Cards for Use in M2M/IoT Devices Meant for Export”.
Official document:
https://www.trai.gov.in/sites/default/files/2025-12/Recommendation_30122025_0.pdf

Through these recommendations, TRAI proposes a new International M2M SIM Service Authorisation under the Telecommunications Act, 2023. This authorisation would allow Indian manufacturers to embed foreign telecom operators’ SIM or eSIM cards in IoT devices meant only for export.

At first glance, this move appears sensible. After all, export-bound devices must work immediately in foreign markets. Therefore, using foreign SIMs reduces delays and lowers costs.

However, a critical provision changes the risk picture. Specifically, TRAI allows foreign SIM/eSIM cards to be activated inside India for up to six months for testing. As a result, devices that are physically located in India may operate on foreign networks.

This is where trade facilitation meets data sovereignty, a concern already explored by ABC Live in its detailed explainer on India’s data sovereignty strategy:
https://abclive.in/2025/08/29/explained-indias-role-in-data-sovereignty/

Why IoT Connectivity Carries Strategic Risk

Market Scale Makes Small Gaps Dangerous

Interpretation:
Because IoT systems operate at a massive scale, even a small regulatory gap can multiply quickly. Consequently, what looks like a minor exception can turn into a systemic risk.

How the TRAI Framework Creates Security Exposure

1. Foreign Network Control from Indian Soil

When a device uses a foreign SIM or eSIM, it connects to a foreign telecom network. As a result, the device follows foreign routing rules and foreign access policies.

Even if message content is encrypted, metadata—such as device identity, timing, and usage patterns—may fall outside Indian jurisdiction. Therefore, control shifts quietly but decisively.

2. Testing Activation Becomes a Vulnerability Window

TRAI permits activation of foreign SIM/eSIM cards in India for up to six months. During this period:

• devices remain inside India,
• connectivity is foreign,
• and oversight depends mainly on compliance declarations.

Consequently, the boundary between “testing” and “operation” becomes difficult to enforce, especially at scale.

3. Metadata Moves First—and Often Unnoticed

IoT devices generate large volumes of non-content data, including:

• telemetry,
• update logs,
• network signals.

However, the recommendations do not state where this data must be stored or processed during testing. As a result, India may lose control over data even before export occurs.

4. Dual-Use Devices Raise Additional Concerns

Many IoT devices serve more than one purpose. For example:

• smart meters reveal usage patterns,
• Industrial sensors show production cycles,
• vehicle trackers expose movement logic.

If such devices are tested in Indian conditions using foreign networks, they may reveal infrastructure behaviour, even without malicious intent.

5. eSIM Flexibility Without Clear End-of-Life Rules

eSIMs can be reprogrammed remotely. Yet, TRAI’s framework does not require:

• confirmed deactivation after testing,
• proof that foreign profiles are removed,
• full audit trails.

Therefore, testing profiles could remain active longer than intended.

Comparative Perspective: How Other Jurisdictions Handle IoT Security

Risk Pathways Under the Indian Proposal

India vs EU vs China: Different Priorities

Interpretation:
While India focuses on speed and simplicity, the EU and China prioritise control before scale. This difference is strategic, not accidental.

What TRAI Did Not Address

• No mandatory device security standards
• No data or metadata localisation during testing
• No interception or security visibility rules
• No risk-based device classification
• No mandatory eSIM deactivation proof
• No formal security-agency coordination

As a result, several key risks remain unmanaged.

What DoT Must Add Before Notification

Before notifying the framework, the Department of Telecommunications (DoT) should introduce binding safeguards:

1. Register and isolate testing facilities
2. Ban testing on live Indian infrastructure
3. Require local storage of testing data
4. Ensure lawful interception visibility
5. Classify devices by risk level
6. Mandate eSIM deactivation certificates
7. Coordinate with security agencies

Without these steps, facilitation may turn into exposure.

ABC Live Evidence Box

How We Verified This Report

This report relies on:

• TRAI’s official recommendation dated 30 December 2025
  https://www.trai.gov.in/sites/default/files/2025-12/Recommendation_30122025_0.pdf

• Statutory context under the Telecommunications Act, 2023

• TRAI consultation materials and timelines

• Public EU and China IoT security frameworks

• Global IoT market data from recognised research bodies

All sources are public and verifiable. Interpretations are editorial.

Conclusion: Speed Without Safeguards Is a Risk

TRAI’s framework clearly supports exports. However, by treating connectivity mainly as a trade input, it risks overlooking its role as a control layer.

Exports bring quick gains.
Security gaps grow slowly—and then suddenly.

The notification stage is therefore decisive. If safeguards are not added now, fixing the damage later may be impossible.