M2M Regulation

Issues

Machina Resarch identifed the following themes

Permanent roaming

The ability to offer services globally is a critical one for supporting many vertical sectors including automotive and consumer electronics. Regulatory prohibition of permanent roaming will fundamentally influence how connectivity is provided.

National roaming

The ability to make use of multiple networks within a territory will be useful for many M2M and IoT applications. However, regulatory positions vary with some countries prohibiting the use of national roaming.

Spectrum licensing

Technology choices for delivering M2M and IoT services may depend on what, how, and how much, spectrum is made available. The availability of White Space might have an influence of how M2M/IoT evolves, while there are licensing issues related to the use of alternative technologies such as Low Power Wide Area (LPWA).

Numbering

Several regulators have opted to allocate a dedicated number range for M2M. ITU has a E.164 numbering plan. This provides for geograhic based as well as international services and networks.

Data sovereignty

Different countries have starkly different rules about how data needs to be managed, for instance restrictions on whether the data can leave the country.

Data privacy

There have been some very high-profile instances of regulation relating to personal data (e.g. the ‘right to be forgotten’ in the EU). Many of these issues relating to personal data privacy will have implications also for M2M and IoT.

Other regulatory issues: There are a number of other regulatory issues, including subscriber registration and taxation that will have an impact on M2M and IoT.

IP based Voice

<ref>From Wikipedia DNS mapping of E.164 numbers/ref> Some national telephone bodies or telephone companies have implemented an Internet-based database for their numbering spaces. E.164 numbers may be used in the Domain Name System (DNS) of the Internet in which the second-level domain e164.arpa has been reserved for telephone number mapping (ENUM). In the system, any phone number may be mapped into a domain name using a reverse sequence of subdomains for each digit. For example, the telephone number +19995550123 translates to the domain name 3.2.1.0.5.5.5.9.9.9.1.e164.arpa.[3]

M2M Service Providers

In India TRAI has taken over regulation for IoT. This is unusual as TRAI originally was only to act as a regulator among licensed telecom operators. As a result of its consultation launched 2013 came out with a draft recommendation in 2015 which requires M2M service providers (M2MSP) registration. M2MSP pay a processing fee of Rs 10,000 and a bank guarantee of Rs 10 lakh.

List of specified M2M Services

The illustrative list of M2M services are <ref> Annexure 1 M2M Service Providers Registration (Draft Guidelines May 2016)</ref> Providers of such services need a OSP (Other service provider ) license from TRAI and need to register as a M2M Service Provider

1. Automotive
2. Fleet management
3. Supply chain management
4. Smart Utilities including Power, Water, GAS, Garbage disposal
5. Healthcare
6. Agriculture
7. Smart cities
8. Smart Home/ Building
9. Safety and surveillance
10. PoS- Fiscal Register
11. Portable consumer Electronics/ Wearable devices

Internet and Cellular only approach

The regulation require a registration of each provider of such services and a fee has to be paid. Medianama has a good summary which is reproduced below. Note the following

• TRAI assumes a SIM card based connectivity and KYC
• TRAI requires Internet based last mile connectivity

There has been some feedback at TRAI needing to be open to innovation as the last mile is undergoing significant change with low power wide area network LPWAN,and even 3GPP the cellular body realizing the need for narrow band IoT appropriate protocols like NB-IOT. Some rethink is likely

Medianma Summary

The policy and regulatory guidelines laid out by the DoT:

Registration of M2M service providers with DoT

All M2M service providers using telecom facilities from Telecom Service Providers (TSPs) should have MSP (M2M service provider) registrations which will let the DoT address issues of KYC, interface issues with TSPs, security and encryption for lawful interception of data. MSPs will be governed by DoT guidelines related to communication infrastructure and regulations of the industry vertical they operate in. The terms, conditions and guidelines of the MSP registration process are yet to be released.

KYC norms for M2M services

M2M service providers will only get SIMs issued from TSPs after fulfilling requisite KYC norms as required in case of corporate connections. The ownership of all such SIM cards will be with the M2M service provider and the details of all the customers of the M2M service which are in physical possession of machines fitted with these SIMs, will be maintained by the M2M provider. The M2M service provider will also be required to maintain updated info regarding details of end devices, make, model, registration number etc of the machines, and the address of the physical custodian of the machine, to TSPs, which will ensure traceability of M2M SIMs.

Permanent International Roaming

The DoT mentions that imported cars for example, with foreign telecom operators SIM, will ensure the SIM is in permanent roaming and the KYC details of the car will never get updated with Indian TSPs. As a workaround, the DoT suggests a reasonable notice time be given to those selling devices or vehicles fitted with foreign SIMs, to enable them to enter into commercial arrangements with Indian TSPs. Other than this, the agency suggests the overall foreign SIM cards should not be permitted in the devices to be used in India.

SIM transfer

As mentioned in the KYC norms section above, M2M service providers will be in charge of the SIM cards handed over to end users. However, there is a possibility that end-users could remove the SIM and use their own. The DoT suggests that M2M service providers also be MVNO with separate IMSI loc of their own, which will let end-users change the TSP without needing to physically change the SIM. Such an arrangement is currently implemented in Brazil. The DoT suggests the use of soft or virtual SIMs, as it will facilitate the change of TSPs at consumer discretion.

Security issues

The DoT addresses security concerns at three levels, namely

• the M2M data within a telecom operator’s domain: For this, TSPs are already limited to providing data transfer mechanism from end devices to M2M and hence existing security and encryption related regulation currently in place are enough.
• the M2M data within M2M service provider’s domain: For data in the service provider’s domain, the data collections rules will be regulated by architecture standards, on which One M2M alliance and TEC working groups are currently deliberating. These standards in conjunction with IT Act governing current data service will be enough for ensuring security among service providers.
• and security at sensor/device level: At the sensor/device level, only genuine IMEIs should be used like in existing handsets and IMEIs guidelines for handsets will be applicable for M2M devices as well.

Health/Safety regulations and environmental guidelines

According to the DoT, with millions of devices connected mostly via wireless, it may have an impact on human health. The agency makes the following suggestions to address the issue:

• M2M device’s RF and radio emission standards have to be under safe zones including compliance to standard levels of SAR- Specific Absorption Rate, CE, Radiation norms for mobile handsets etc.
• M2M devices shall have lower power consumption and shall be targeted to meet highest energy ratings published by relevant standardization bodies.
• Technical specifications for M2M sensors shall be referenced from existing guidelines applicable for mobile handsets, consumer electronics safety requirements etc.
• M2M Devices should be made of biodegradable material which can be recycled easily.
• M2M devices must adhere to industry and standards body specifications for emission, safety and integrity of services.
• Efforts should be made to meet global standards on environmental guidelines for the ICT sector including Dow Jones Sustainability Index (DJSI), GHG Protocol Corporate Standard, Global Reporting Initiative (GRI), ISO TC 207, ISO 14031, ISO 14064-1, and IEC TC 111.

Location and connectivity guidelines

As for these guidelines, all M2M services will have to be based on IP (internet protocol) only so as to encourage adoption of a common standard. Additionally, all M2M gateways and application servers, servicing customers in India will need to be located in India

M2M Service Provider Definitions

From TRAI draft notification

M2M Services

means the services offered through a seamless connected network of embedded objects/devices, with identifiers, in which Machine to Machine (M2M) communication without any human intervention is possible using standard and interoperable communication protocols. These includes providing services like Vehicle automation, e-Health, Agriculture automation, Fleet management, Supply chain management OR any other services identified by the Authority from time to time as specified in Annexure I by converging physical infrastructure (e.g. buildings, roads, vehicles, transportation, power plants) and digital infrastructure (IT and Communications infrastructure).

M2M arrangements

involve communication of end device with predefined back end platforms either directly or through some gateway. Most of the M2M implementations involve end devices tightly coupled with the platform either directly or through gateway. M2M end device and platform collecting and analyzing information from end device are controlled by some entity/ organisation. That entity/ organisation is termed as “M2M Service Provider” (M2MSP).

Telecom Resource

means Telecom facilities used by the M2MSP including, but not limited to Public Switched Telecom Network (PSTN), Public Land Mobile Network(PLMN), Integrated Services Digital Network (ISDN) and/or the telecom bandwidth provided by authorized telecom service provider having valid licence under Indian Telegraph Act, 1885.

Licensee

means a registered Indian Company that has been awarded License to provide service(s) authorized under the License, within the geographical boundaries of the specified Service Area.

Other Service Provider (OSP)

means a company providing Application Services and is having a valid OSP registration from Department of Telecommunications

Types of license

Earlier licenses were fixed licence fee and specific to technology and usage.

1999

Allowed licensees to migrate from a Fixed Licence Fee Regime to a Revenue Arrangement Scheme (w.e.f. 1/08/1999). Under the new scheme a licence fees was collected as proportional tax on the service provider’s revenue. This covered

1. Cellular Mobile Service Providers (CMSPs);
2. Fixed Service Providers (FSPs) and Cable Service Providers, collectively referred as ‘Access Providers’;
3. Radio Paging Service Providers;
4. Public Mobile Radio Trunking Service Providers;
5. National Long Distance Operators;
6. International Long Distance Operators;
7. Global Mobile Personal Communication by Satellite (GMPCS) Service Providers;
8. V-SAT based Service Providers

2016

CSL Cellular Services License

UASL Unified Access Service License

can provide wireline as well as wireless services in a service area. Wireless services include Full Mobile, Limited Mobile and Fixed Wireless services. The licensee can also provide various Value Added Services . A restriction for authentication of subscriber terminal has been placed. In case of Limited Mobility facility based on Short Distance Charging Area Linked Numbering Scheme. However, same facility without any restriction can be availed by adopting numbering plan for Cellular Mobile Services and using Home Zone Tariff Schemes. Basic and Cellular Services Licensees are permitted to migrate to Unified Access Services Licence regime. The service providers migrating to Unified Access Services Licence will continue to provide wireless services in already allocated/contracted spectrum and no additional spectrum will be allotted under the migration process for Unified Access Services Licence.

UL Unified License

operators are free to provide, within their area of operation, services which cover collection, carriage, transmission and delivery of voice and/or non-voice messages over Licensee's network by deploying circuit and/or packet switched equipment. Further, the Licensee an also provide Voice Mail, Audiotex services, Video Conferencing, Videotex, E-Mail , Closed User Group (CUG) as Value Added Services over its network to the subscribers falling within its service area on non-discriminatory basis. The Licensee cannot provide any service except as mentioned above, which require a separate licence. However, an intimation before providing any other value added service has to be sent to the Licensor and TRAI.

TSP Telecom Service Provider

OSP Other Service provider

See Also

• http://www.trai.gov.in
• National Telecom M2M Roadmap First Published: May 2015
• Can regulation influence governance behaviour?

Spectrum