SIM binding push raises more questions

Without clear legal authority, structured consultation, and proportionate design, it risks undermining user trust, innovation, and the very digital growth it seeks to protect

- PRADEEP S MEHTA

INDIA'S MESSAGING PLATFORMS are no longer just tools for personal communication.

They underpin digital commerce, service delivery, and everyday economic participation at scale. As India pushes towards becoming a trillion-dollar digital economy, regulatory decisions affecting this ecosystem carry consequences that extend far beyond narrow questions of compliance. We must aim for optimal regulation using the tool of impact assessment.

The department of telecommunications’ recent move to mandate SIM binding for some messaging applications must hence be evaluated not only through the lens of cybersecurity, but also for its legal clarity, economic impact, and long-term implications for trust and innovation.

The stated objective of SIM binding is to prevent misuse of mobile numbers and curb fraud, impersonation, and unauthorised access. The direction requires messaging apps that use mobile numbers as identifiers to remain linked to a specific SIM. While the intent is understandable, the approach introduces uncertainty. It raises questions about regulatory ambiguity, proportionality, and execution in an economy that has historically operated outside telecom-style compliance frameworks.

The Telecommunications Act, 2023, defines telecom services and the SIM-binding directions flow from newly notified Telecom Cyber Security Rules. The Act is designed to regulate licensed telecom providers, and OTT messaging services are not licensed telecom service providers. They have traditionally been regulated under the Information Technology Act, 2000. Extending telecom-style obligations to OTT platforms without explicit legislative authority risks failing basic tenets of legality and proportionality.