TRAI releases Recommendations on ‘The Framework for Satellite Communication Network Provider Authorisation, and Assignment of Spectrum to Satellite Communication Network Providers'

1. At a Glance

• TRAI has recommended a new SCN Provider Authorisation. It creates a network-layer player that builds satellite network capacity and supplies it to service providers as SCNaaS (Satellite Communication Network as a Service). SCN providers may not serve end users directly [1].
• The framework covers spectrum for both feeder links and user links. It is assigned administratively and is tied to the First Schedule of the Telecommunications Act, 2023 [1][2].
• It opens two routes for Direct-to-Device (D2D) satellite service: MSS-based (L and S bands) and IMT-based (on a non-interference, non-protection basis). This is directly relevant to rural connectivity and disaster resilience [1].
• UPSC relevance: The topic brings together the 2023 Act, a statutory regulator, the auction-versus-administrative spectrum debate, the space economy and digital inclusion (GS-II and GS-III) [1][2].

2. Why in the News

• On 05 Nov 2026, TRAI released its recommendations on "The Framework for SCN Provider Authorisation, and Assignment of Spectrum to SCN Providers" [1].
• They answer a DoT reference dated 03.07.2025 [1].
• They follow a consultation paper (08.04.2026) and an open house discussion (02.07.2026) [1].

3. Background & Evolution

• The Telecommunications Bill, 2023 was introduced in Lok Sabha on 18 Dec 2023 [2].
• It repeals the Indian Telegraph Act, 1885, the Indian Wireless Telegraphy Act, 1933 and the Telegraph Wires (Unlawful Possession) Act, 1950, and amends the TRAI Act, 1997 [2].
• It requires prior authorisation to (i) provide telecom services, (ii) establish, operate, maintain or expand telecom networks, and (iii) possess radio equipment [2].

• Spectrum is assigned by auction by default. Specified uses get administrative allocation, including satellite services such as DTH and satellite telephony [2].

• Milestones:

• 03.07.2025: DoT seeks TRAI's recommendations on the SCN authorisation framework [1].
• 2025: The NFAP 2025 becomes the reference allocation plan for the assignment [1].
• 2026: The Telecommunications (Authorisation for Provision of Principal Telecommunication Services) Rules, 2026 are framed. They supply the ApGR approach and the list of eligible licences [1].

• 08.04.2026: Consultation paper; 02.07.2026: open house discussion; 05.11.2026: recommendations released [1].

• Predecessors: Satellite capacity is already held under the Unified License, the Sui-Generis gateway licence and 2026 Rules authorisations. Holders of these may also provide SCNaaS if they meet the SCN eligibility conditions [1].

4. Core Static Facts

Key terms

• Feeder link: connects the satellite to the gateway [1].
• User link: connects the satellite to the end user [1].
• Partnering-entity spectrum: an SCN entity may use a partner service provider's spectrum only for SCNaaS. The right to use stays with the partner, so the spectrum is shared, not transferred [1].
• Revenue terms: GR (gross revenue) → ApGR (applicable gross revenue, which excludes non-telecom revenue) → AGR (adjusted gross revenue, after deducting gateway charges and GST) [1].

5. Multi-Dimensional Analysis

Economic

• Regulatory parity: The vertically integrated and unbundled (SCNaaS) models are treated alike. SCNaaS charges paid by a service provider are deductible from its ApGR, which prevents double levy [1].
• Non-telecom revenue is excluded from ApGR, which narrows the levy base [1].
• An 8% fee with no minimum and a low per-MHz floor (Rs 3,500) keeps entry barriers low for new space-economy firms [1].
• The unbundled model lets access providers buy satellite capacity without owning constellations, which supports capital-light expansion [1].

Legal / Constitutional

• The authorisation is anchored in Section 3(1)(b), and eligibility is tied to the First Schedule [1].
• Auction is the default under the 2023 Act. Administrative assignment for satellite services is a statutory exception [2].
• Article 4.4 of the ITU Radio Regulations is used to allow IMT-based D2D on a non-interference, non-protection basis without waiting for WRC-27 [1].

Scientific / Technological

• Feeder and user links are assigned separately [1].
• GSO and NGSO satellites have different permitted bands [1].
• MSS-based D2D uses the L and S bands. The Government is to encourage handset makers to include MSS-band modules [1].
• For IMT-based D2D, MSS is added as a secondary service in NFAP, with an India-specific footnote and aggregate electric field strength limits to protect incumbents [1].

Social

• D2D lets ordinary handsets connect directly to satellites. This supports last-mile coverage of remote, hilly and island areas [1].
• Satellite links remain available when terrestrial networks fail, which improves disaster communication [1].

Governance / Administrative

• The process is consultative: a consultation paper, then an open house, then recommendations [1].
• IMT-based D2D needs consensus among IMT licensees across all 22 LSAs. This is a coordination bottleneck [1].
• Implementation depends on DoT accepting the recommendations and amending NFAP 2025 [1].

Geopolitical / Strategic

• India is moving on D2D ahead of WRC-27 under Article 4.4. That positions its regulation ahead of the global harmonisation timeline [1].
• SCN providers' gateways operate under Indian authorisation. Domestic network control is in line with the 2023 Act's broader security powers, such as interception and temporary possession in a public emergency [1][2].

6. Recent Developments (last 12–18 months)

• 03.07.2025: DoT reference to TRAI [1].
• 2025: NFAP 2025 in force as the allocation baseline [1].
• 2026: The Telecommunications (Authorisation for Provision of Principal Telecommunication Services) Rules, 2026 serve as the source of the ApGR approach [1].
• 08.04.2026: TRAI consultation paper [1].
• 02.07.2026: Open house discussion [1].
• 05.11.2026: TRAI recommendations released [1].

7. Prelims Hooks

• The SCN Provider Authorisation is granted under Section 3(1)(b) of the Telecommunications Act, 2023 [1].
• SCN providers cannot provide telecom services directly to end users. They supply capacity via SCNaaS [1].
• SCN authorisation is national in area and lasts up to 20 years, renewable for up to 20 years [1].
• The spectrum assignment period is up to 5 years, extendable by up to 2 years [1].
• The Authorisation Fee is 8% of AGR, with no minimum fee [1].
• The Minimum Spectrum Charge is Rs 3,500 per MHz per year [1].
• Feeder link spectrum is FSS, assigned administratively [1].
• User link spectrum is FSS and/or MSS [1].
• NGSO systems get no C band for FSS user links [1].
• MSS-based D2D uses the L and S bands [1].
• IMT-based D2D runs on a non-interference, non-protection basis under Article 4.4 of the ITU Radio Regulations, without waiting for WRC-27 [1].
• For IMT-based D2D, MSS is added as a secondary service in NFAP, with an India-specific footnote [1].
• IMT-based D2D needs the agreement of the relevant IMT channel holders across all 22 licensed service areas [1].
• SCNaaS charges are deductible from ApGR, and non-telecom revenue is excluded from ApGR [1].
• The Telecommunications Bill, 2023 was introduced in Lok Sabha on 18 Dec 2023. It repealed the Indian Telegraph Act, 1885 [2].

8. The 2G Objection, and Why It Only Partly Applies Here

• The strongest objection: this looks like 2G again
• In the 2G case, the Supreme Court cancelled 122 licences. It held that giving out natural resources on a first-come-first-served (FCFS) basis was unconstitutional [6].

• Satellite spectrum here is also given by the government directly, not by auction. So a critic asks: will the public again get less than the spectrum is worth?

• The answer: this time Parliament itself made the exception

• Section 4(4) of the Telecommunications Act, 2023 makes auction the rule. Only the entries in the First Schedule are assigned administratively (by a government decision, not bidding) [9][5].
• The Schedule already names satellite services such as DTH, VSAT, GMPCS (satellite phone service) and MSS in the L and S bands [7].

• The government's Presidential Reference after 2G asked whether courts can order auction for every natural resource. Some argued the Court had no power to give that order [6]. So auction was never accepted as the only lawful method.

• What the critic gets right: the government can grow the non-auction list alone

• Under Section 4(5), the government can add entries to the First Schedule by notification. It can do this for public interest, for government functions, or where auction is not suitable for technical or economic reasons [5].
• The notification is only "laid before" Parliament, which means placed on the table. The brief does not say a vote is needed [5].

• So the main check on fairness moves from the auction to the price formula. The Rs 3,500 per MHz per year floor [1] now does the work that bidding would have done.

• What should follow: DoT should publish how the satellite spectrum floor was worked out and when it will be reviewed. Without that, the price cannot be checked the way an auction result can.

9. Satellite vs Mobile Operators: The Fight Over Equal Rules

• DoT itself asked for a level playing field
• DoT's July 2024 reference asked TRAI to price satellite spectrum keeping a level playing field with terrestrial access services (mobile and fixed networks on the ground) [4].

• Mobile operators get spectrum by auction [2]. Satellite players get it administratively and pay a yearly charge [1]. So the two pay under different cost rules.

• D2D brings satellites into the same customer's pocket

• Once an ordinary phone can connect straight to a satellite, the satellite network and the mobile operator are selling to the same person.
• That is why IMT-based D2D needs the consent of the IMT channel holders in all 22 LSAs (licensed service areas, the telecom circles) [1]. IMT is the band family mobile operators bought for 4G/5G.

• The consent rule protects operators who paid at auction. But it also lets a rival decide whether a competitor can enter.

• The price underneath is still not settled

• In May 2025, TRAI recommended satellite spectrum charges of 4% of AGR (adjusted gross revenue, the revenue on which levies are counted), with a per-MHz minimum, for NGSO FSS and MSS [3].
• DoT sent some of those recommendations back on 12.11.2025. TRAI replied in December 2025 [4].
• A 2026 Lok Sabha answer says the government accepted only some TRAI recommendations, and some licensees got spectrum only on a provisional basis [8].
• So the SCN framework's spectrum charge rests on satellite pricing that is still partly provisional.

10. Why TRAI's Recommendations Keep Coming Back to It

• TRAI recommends; DoT can send the advice back

• DoT asks for TRAI's advice under Section 11(1)(a) of the TRAI Act, 1997 [4]. The advice does not bind DoT. DoT can return it with a back-reference (a request to reconsider).

• This has happened again and again under the 2023 Act

• Service authorisations (recommended 18.09.2024) were sent back [11].
• Network authorisations (recommended 17.02.2025) were sent back on 03.07.2025 [10].
• Satellite spectrum terms (recommended 09.05.2025) were sent back on 12.11.2025 [4].

• DoT's reference for this SCN framework is dated 03.07.2025 [1], the same day as the network authorisation back-reference [10].

• Why it matters

• Each round of back-and-forth adds months. Until DoT accepts the advice, none of the fees, tenures or band rules in this note is binding.

• A satellite company cannot plan capital spending on terms that may change at the next back-reference.

• What should follow: DoT should first settle the satellite spectrum pricing still open from the May 2025 recommendations [3][4], then notify SCN rules on top of it. Otherwise two connected frameworks may move on different timelines.

11. Where Direct-to-Device Service Can Get Stuck

• The disaster backup has the weakest claim on the airwaves
• IMT-based D2D runs on a non-interference, non-protection basis [1]. It must not disturb anyone else. If someone else disturbs it, it has no legal protection.

• So the service promoted for disaster communication is the one regulators are least bound to protect.

• One area can block the whole country

• SCN authorisation is national [1]. But IMT-based D2D needs agreement from channel holders in all 22 LSAs [1].

• If the holder in even one LSA refuses, a single nationwide D2D service cannot launch on that channel.

• The MSS route is legally clearer but blocked at the phone

• MSS in the L and S bands is already in the First Schedule [7]. So MSS-based D2D needs no change to the law.
• But ordinary phones need an MSS-band module. The government will only "encourage" handset makers to add it [1]. It is not a rule.

• Until phones carry the module, MSS-based D2D reaches only the few who own such phones.

• What should follow: DoT must amend NFAP 2025 (India's plan for which band is used for what) to add MSS as a secondary service [1]. IMT-based D2D cannot start legally before that.

12. Anchors for Answers

• Data: Rs 3,500 per MHz per year: the minimum spectrum charge for SCN providers [1]
• Data: 4% of AGR, with a per-MHz minimum: TRAI's May 2025 recommended charge for NGSO FSS and MSS spectrum [3]
• Data: 122 2G licences cancelled by the Supreme Court for FCFS allocation [6]
• Report/Committee: TRAI Recommendations on Terms and Conditions for Assignment of Spectrum for Certain Satellite-Based Commercial Communication Services (09.05.2025), sent back by DoT on 12.11.2025 [3][4]
• Law/Case: Section 4(4) and 4(5), Telecommunications Act, 2023: auction is the default, the First Schedule lists the exceptions, and the government can amend it by notification [5][9]; the 2G judgment and the Presidential Reference that followed [6]

13. Mains Relevance

• GS-III: Infrastructure (telecom); Science & Technology (awareness in the fields of IT and space); Indian economy (resource mobilisation, such as spectrum pricing).
• GS-II: Statutory, regulatory and quasi-judicial bodies (TRAI); government policies and interventions; issues arising from their design and implementation.
• Question stems: 1. The unbundling of satellite network provisioning from service provisioning through 'SCN-as-a-Service' marks a structural shift in India's telecom regulation. Examine its implications for competition and rural connectivity. (GS-III, 250 words) 2. Critically evaluate administrative assignment versus auction of satellite spectrum in light of the Telecommunications Act, 2023. (GS-III) 3. Direct-to-Device satellite connectivity can transform disaster communication and last-mile inclusion. Discuss the regulatory and technological challenges in its rollout in India. (GS-III)

14. Related Topics to Study Next

• Telecommunications Act, 2023: the enabling law, covering authorisation, spectrum, interception and right of way [2].
• National Frequency Allocation Plan (NFAP) 2025: the governing spectrum allocation document, to be amended for D2D [1].
• ITU Radio Regulations and WRC-27: the global spectrum regime; Article 4.4 is the basis for interim D2D [1].
• Indian Space Policy, 2023 and IN-SPACe: the authorisation of private satellite operators that SCN providers depend on.
• AGR definition and the telecom levy regime: links to the AGR dispute and the Supreme Court judgment.
• BharatNet and the Digital Bharat Nidhi: terrestrial last-mile connectivity that complements satellite reach.
• Satellite internet constellations (LEO/NGSO): understand the technology that NGSO band rules apply to [1].
• Disaster communication (NDMA): a use case for D2D and MSS.

15. NCERT Concepts to Revise

• Telecommunications Act 2023 (Polity): The SCN authorisation, auction-versus-administrative assignment and First Schedule exceptions all come from this Act.
• Spectrum (Economy): The whole note is about how satellite spectrum is assigned, priced and shared with mobile operators.
• Telecom Regulatory Authority of India (Polity): TRAI makes these recommendations, but DoT can reject them or send them back for reconsideration.
• Adjusted gross revenue (Economy): The 8% authorisation fee is charged on AGR, so you need to know how this revenue base works.
• Satellite communication (Geography): Feeder links, user links and direct-to-device service all depend on how satellite communication works.
• Space economy (Economy): SCN providers are new private players in the space economy, and low entry barriers are meant to attract them.

16. Common Errors / Trap Areas

• Recommending vs authorising body: TRAI only recommends. DoT (Central Government) grants authorisations and assigns spectrum [1].
• Section mix-up: The SCN authorisation is under Section 3(1)(b), which covers networks, not services [1][2].
• SCN provider ≠ service provider: SCN entities cannot serve end users directly [1].
• Tenure confusion: 20 years is the authorisation tenure; 5 (+2) years is the spectrum assignment period [1].
• GR, ApGR and AGR: ApGR removes non-telecom revenue. AGR further deducts gateway charges and GST [1].
• IMT-based D2D does not wait for WRC-27. It proceeds under Article 4.4 on a non-interference, non-protection basis [1].
• NGSO and C band: NGSO gets no C band for FSS user links [1].