DOT's Miscellaneous Authorisations: A Quiet but Significant Shift in India's Telecom Licensing

Shatakshi Shekhar, Shradhanjali Sarma

The Department of Telecommunications (DoT) has quietly released a draft rules on September 15, 2025, that could reshape how India regulates a swathe of niche telecom services, machine-to-machine (M2M) connectivity, public Wi-Fi (PM-WANI), and a cluster of other miscellaneous authorisations. At first glance, this might look like bureaucratic housekeeping which it isn't. This draft tells us a lot about where India's telecom policy is headed: consolidation of licensing, a preference for light-touch regulation where market incentives exist, and a subtle but unmistakable push to bring every communications service, however small, under a single legal framework.

From Patchwork to One Framework

India's telecom licensing has long been a patchwork of separate approvals. M2M providers sought one set of guidelines, public Wi-Fi entities another, and niche services like satellite messaging still another. The draft notification folds these disparate permissions into a single, clearly titled Authorisation for Provision of Miscellaneous Telecommunication Services under the new Telecom Act 2023. This shift reflects a fundamental move from traditional licensing to authorization regimes which as per research has shown, can enhance market competition while maintaining oversight. As noted in an Oxford Research, general authorisation regimes are not subject to licensing requirements and have no set licence duration, facilitating market entry and innovation.

Viewed alongside the new Telecommunications Act of 2023, this notification reinforces a clear regulatory trajectory. It reflects a drive toward convergence, bringing all forms of communication like traditional telecom networks, satellite broadband services, and even PM-WANI Wi-Fi hotspots, under a single legislative umbrella. At the same time, it underscores a centralisation of control: even light licences retain strong national-security override provisions. The draft rules fit squarely within the 2023 Act’s framework, which sets out conditions for authorisation validity, security requirements, satellite usage, and the migration of existing licences. For investors, the message is one of predictability. A 20-year licence term with clearly defined conditions reduces regulatory uncertainty, which is an essential factor for capital-intensive Internet of things (IoT) and satellite ventures. It is the same playbook we have already seen with unified licences and the draft spectrum-sharing rules: simplify and reduce fragmentation, but maintain firm oversight.

This is more than administrative tidiness. By creating a formal authorisation category, DoT is saying: if you provide connectivity of any kind, you live inside the Act. That simplifies compliance for service providers and gives the government a clearer legal handle on fast-evolving sectors such as IoT connectivity and community Wi-Fi.

Light-Touch with Conditions

The draft preserves a light-touch approach under which the government will now authorize eligible applicants without a letter of intent for PM WANI and M2M services, eliminating bureaucratic steps that added months to approval processes. There's no entry fee, no performance bank guarantee, and a 20-year term with straightforward renewal. For small PM-WANI providers and M2M players, that's welcome. While the entry barrier is low, the conditions and obligations are not trivial.

Security and KYC: Providers must maintain subscriber records and enable lawful interception. For small Wi-Fi entrepreneurs, those obligations can be operationally heavy.

Financial reporting: Even when fees are nil, quarterly compliance filings and audits remain mandatory. Companies have to report any changes in shareholding patterns, company name, and ownership to the government—representing the authorization model's trade-off of easier entry for ongoing transparency.

Revocation powers: The government retains sweeping powers to suspend or revoke authorisation in the interest of national security, a phrase that has rarely been narrowly construed.

Implications for Key Segments

M2M/IoT Connectivity: India's connected-device market is set to explode, from smart meters to vehicle telematics. Companies registered under the Companies Act, 2013 are the main eligible entities for obtaining M2M Authorization, with MoA objectives relating to M2M activities. This brings clarity, but it also means start-ups cannot stay off-licence by merely riding on a telecom partner's network.

PM-WANI Wi-Fi: PM-WANI was conceived as a truly unlicensed, entrepreneurial model to spread cheap Wi-Fi. The framework has undergone significant evolution since the DoT made amendments to the PM-WANI framework on 16 September 2024, removing the requirement for PDOs to enter into commercial agreements with TSPs for internet connectivity. This draft builds on those reforms, preserving the entrepreneurial vision while formalising it within the Act. While investor comfort shall be easier with the statutory recognition of the model, there but also heightened compliance expectations.

Niche Services (In-Flight, In-Ship, Satellite Messaging): By sweeping them into a single authorisation, DoT is future-proofing regulation. As low-earth-orbit satellite players enter India, this framework could be the default path to market.

Questions the Draft Leaves Open

One area of uncertainty concerns future fees. At present, there is no entry fee or revenue-share obligation for the new authorisation. However, the draft includes a clause allowing the government to modify terms in the public interest. That language leaves open the possibility that new fees could be introduced later, a point investors and service providers should examine carefully.

Another question is how this framework will interact with the Telecom Regulatory Authority of India’s (TRAI) existing work. TRAI has already issued separate recommendations on M2M numbering and quality-of-service standards. The draft does not explain how those recommendations will align with the new authorisation, and operators will want clarity before they invest heavily.

Finally, the draft sits alongside India’s new Digital Personal Data Protection (DPDP) Act, which imposes strict obligations on the handling of personal data. The authorisation still requires interception capabilities and customer-identity verification. It remains unclear how these interception and KYC obligations will reconcile with the privacy protections mandated by the DPDP Act. None of these issues are fatal flaws, but they merit thoughtful public comment before the rules are finalised.

Conclusion

Telecommunications regulation can seem slow and procedural, but it forms the plumbing of the digital economy. India’s ability to meet its ambitions for the IoT or to sustain leadership in affordable public Wi-Fi depends on frameworks like this one. By moving early to consolidate emerging services under a single authorisation, the Department of Telecommunications is betting that clarity and light-touch oversight will encourage investment. The challenge will be to preserve that light touch and prevent the framework from hardening into another heavy licence over time.

The shift from traditional licensing to an authorisation model is more than a procedural change; it reflects the reality that twenty-first-century digital infrastructure needs regulatory frameworks capable of keeping pace with rapid technological evolution. This draft is not merely a bureaucratic clean-up. It signals how India intends to regulate the edges of its telecom ecosystem: one law, one licence, and if stakeholders press their case, a genuinely enabling environment for the next wave of connectivity.