The Department of Telecommunications (DoT) has drafted a M2M (Machine to Machine) policy roadmap which will determine and define the approach towards M2M adoption in the country. The roadmap is based on a questionnaire the DoT released for industry stakeholders to respond to, the answers to which were to be submitted by 11th October 2013.

The guidelines aim to establish M2M communication standards and release national M2M numbering plans within this year, other than addressing the issues of M2M quality of service, M2M roaming requirements, M2M service provider registration process, guidelines for specifics like KYC, SIM transfer etc., forming an apex body for inter-ministerial coordination, to establish centers of innovation, boost M2M products and services and define procedures for energy rating of M2M devices and its implementation.

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.

– Issues facing the Indian M2M environment:

According to the DoT, M2M and policies and regulations are just evolving and global standards are only just being framed. As such this will lead to various issues for regulators and policy makers in the future. With this in mind, the agency has listed some of the issues in context of the Indian M2M environment. These issues include:

M2M spectrum requirement: The DoT acknowledges that there may be a need to fine-tune free spectrum bands. Requirements under consideration by the agency include the de-licensing of frequency bands 24-24.25 Ghz, 76-77 Ghz, 77-81 Ghz for vehicular radar, and requirement of import license for short distance and small power output devices.

Define frequency range for PLC communication: PLC technology is at the nascent stages in India as far as M2M products and services are concerned. The technology can be used for last mile connectivity and to create wide area networks. The agency will allocate frequency bands for both, narrowband and broadband PLC communications, and will discuss the issue with relevant stakeholders.

M2M numbering plan: The DoT will consider a new M2M numbering scheme so as not to run short of addresses, which will cover the following items:

  • MSISDN less subscription/ Dummy MSISDN based subscription
  • Requirement of unique/ dedicated IP scheme and/ or APN.
  • ESN of the devices to be made mandatory part of communication protocol
  • Linking of IP/ MAC addresses with IMSI/ numbering to get unique numbering
  • Identification of category of M2M devices for ensuring service segregations by numbering Scheme
  • Supporting more than one naming scheme
  • Single numbering scheme irrespective of local/ national/ international roaming
  • E.164 & E.212 addressing scheme adoption

M2M roaming requirements: Roaming guidelines for SIMs based in devices will be the same as those for voice and data services. TSPs can enter into agreements with foreign TSPs to provide roaming facilities and vice versa. However, roaming subscribers can only access services to which they have subscribed in their home networks.

Cloud use for M2M: Issues related with cloud use are related to the whole telecom sector, as TSPs have been referring to the issue that they are not allowed to route telecom traffic for India through a foreign country. The DoT concludes that as and when these issues will be resolved, they will be applicable to M2M as well.

Capturing SIM details/ mobile number as registration: The DoT is proposing that for SIM based M2M services, respective registrar or authorities should examine the possibility of mandatory capture of SIM details or mobile number as part of the registration. This will improve traceability of the registrant if required.

– Other focus areas:

M2M standard development initiatives: The DoT acknowledges that a common shared architecture for M2M will be required to achieve large scale M2M deployment. The TEC (telecommunication engineering centre), the technical arm of DoT has started working on India specific M2M standards and has formed five working groups to start with, including power, automotive, surveillance, health and M2M gateway and architecture. Additional working groups may be created based on industry and government requirements.

Inter-ministerial coordination requirements: The DoT is proposing to form an APEX body to address inter ministerial coordination, to address all issues related to M2M. The responsibilities of such a body would include, to have an integrated approach, avoid fragmentation, to address spectrum requirements, to address quality of service in M2M networks and enable information sharing. Other than this, the DoT mentions the industry in India will also need to have a unified structure to air M2M proliferation.

Indigenous products and services: Most startups in India manufacturing and servicing M2M products tend to import basic components like modules, sensors etc. This is because manufacturing in India is low, for which the agency will further promote ‘Make in India’. Other than this the agency mentions test bed facilities will need to be created to serve Indian and international telecom equipment manufacturers, telecom operators, regulators, content and app providers, independent software developers, educational institutes, R&D institutions and chipset manufacturers etc. The TEC will upgrade and fine-tune its existing facilities to meet M2M testing requirements.

M2M products certification: TEC might take up the responsibility of M2M specific product certification with the objective of modularity, scalability, interoperability and roaming among other devices. The TEC claims to already have a number of standards in terms of Generic requirements, Interface requirements and Service requirements. The body will also upgrade and fine-tune its facilities to enable M2M products certification at existing facilities.

M2M capacity building and Centers of Innovation: DoT has already designated NTIPRIT for skill development and suitable course content and for M2M demonstration centres. The agency also proposes a Center of innovation that can develop model experimental M2M networks, implement pilot projects and showcase its technology, develop net applications in M2M and promote R&D as well as IPR creation among other goals. The CoI may be set up independently or part of the upcoming CoI for other domains under the ambit of DoT.

Download: National Telecom M2M Roadmap (pdf)

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