Broadband India Forum Calls for Rethink of DoT’s Cyber Security and SIM Binding Rules

The Broadband India Forum (BIF) has written to the Department of Telecommunications (DoT), seeking a review of the Telecommunications (Telecom Cyber Security) Amendment Rules, 2025 and the related SIM Binding Directive.  

In its communication to DoT Secretary Amit Agarwal, the industry body stated that parts of the new framework may go beyond the scope of the Telecommunications Act, 2023. 

BIF’s submission is based on a legal opinion obtained from a Senior Counsel. The forum said the amendments and subsequent directions introduce obligations that may not be supported by the parent legislation governing telecom networks and services. 

SIM Binding Requirement Comes into Force 

The SIM binding mandate took effect from 1 March. Under this directive, app-based communication services are required to remain linked to an active SIM card inserted in the user’s device. This would restrict the use of messaging platforms without the registered SIM being physically present. 

The directions also require web-based access through laptops and desktops to be logged out at regular intervals, reportedly every 6 hours. The measure follows instructions issued by the DoT under the amended cyber security rules. 

New Category of Regulated Entities 

The directive introduces a new classification called Telecommunication Identifier User Entities (TIUEs). These include companies that rely on telecom identifiers such as mobile numbers, IP addresses, or device IMEIs to identify users or deliver services. 

The category could cover a range of businesses, including banks, fintech platforms, and digital communication service providers.  

TIUEs would be expected to comply with government instructions to block fraudulent identifiers, participate in Mobile Number Verification processes, meet data protection requirements, and cooperate with law enforcement agencies. 

Overlap With Existing Legal Frameworks 

BIF stated that TIUEs are not licensed telecom operators under the Telecommunications Act. It argued that the use of telecom identifiers within digital applications does not amount to providing telecom services as defined by law. 

The forum also flagged possible regulatory overlap with existing statutes such as the Information Technology Act and the Digital Personal Data Protection Act, noting that the new rules could introduce parallel compliance requirements across sectors. 

Government Position 

During a media briefing on 25 February, the Telecom Minister defended the SIM binding directions, describing them as necessary to address cyber fraud and digital security threats. The implementation timeline was retained without extension. 

BIF has requested an urgent review of the framework in light of the legal issues raised. 

Read More: Satcom Boost: India Grants Licences to Starlink, Jio and OneWeb; Pricing Decision Pending! 

Conclusion 

BIF has sought a review of the amendments in light of the issues raised in its submission. It has pointed to the need for clarity on scope and applicability. The matter now rests with the Department for evaluation. 

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