Regulatory State Of Play IoT Machine-to-Machine (M2M) Communications

India has one of the world's most vibrant telecom markets, with more than 1170.45 million telecom subscribers, poised to grow at a compound annual growth rate of 9.4% until 2025. It is somewhat surprising, then, that the laws governing India's telecom boom have been rooted in the 19th century! The Indian Telegraph Act dates back to 1885, and is still the grundnorm for all telecom regulations in India. It is only now, in 2022, that India has proposed a new telecommunications bill to replace the venerable 1885 act.

That India requires a comprehensive framework for telecom regulations is clear. In addition to addressing issues such as spam calls, OTT, etc., an interesting area of regulation would be the use of telecom technology for the Internet of Things ("IoT"). Earlier this year, in July 2022, the current Indian telecom regulator ("TRAI") released a paper on using embedded SIMs for Machine-to-Machine (M2M) communications. This is not the first time the telecom