According to experts, the consultation paper issued by Trai on Wednesday does not have any bearing on Global Mobile Personal Communication by Satellite (GMPCS) service providers such as Starlink, OneWeb and Jio-SES, which are awaiting spectrum pricing guidelines from the government following an earlier consultation by the regulator to launch their services directly to customers. However, the consultation will be crucial for entities that own satellite constellations but do not provide services directly to consumers, offering them flexibility to partner with entities that hold satellite spectrum and function as Satellite Communication Network-as-a-Service (SCNaaS) providers.
“At present, in India, for the provision of satellite-based telecommunication services, service providers are required to deploy ground-based satellite communication networks by themselves. Prima facie, the introduction of the proposed satellite communication network under Section 3(1)(b) of the Telecommunications Act, 2023 may obviate the need for establishing satellite communication networks by service providers. It would functionally delink the service and network layers by allowing service providers to operate at the service layer without investing in or deploying their own satellite communication networks,” Trai said.
Entities holding the proposed SCN authorisation would be permitted to not only establish gateway earth stations but also seek assignment of satellite spectrum from the central government.
In the consultation paper, Trai has asked whether SCN-authorised entities should be permitted to offer their satellite network as a wholesale service to other authorised service providers, and whether virtual network operators (VNOs) should also be eligible to buy such wholesale capacity. On spectrum assignment, the regulator has asked whether SCN entities can hold spectrum directly or through their partnering service providers, and whether spectrum in frequency bands designated for mobile telephony can be assigned to SCN-authorised entities.
“If an entity holding the proposed SCN authorisation seeks the assignment of spectrum for any usage that falls within the scope of any of the entries of the First Schedule of the Telecommunications Act, 2023, it can be assigned spectrum through administrative method,” it added.
Trai has also sought views on eligibility conditions, service areas, validity periods and scope applicable to the proposed SCN authorisation, and the general, technical, operational and security-related terms and conditions that should govern such entities.
On spectrum assignment, Trai has asked whether Fixed Satellite Service (FSS) bands, Mobile Satellite Service (MSS) bands, or even spectrum in frequency bands designated for International Mobile Telecommunications (IMT) should be assignable to SCN-authorised entities. The regulator has also sought views on whether SCN entities should be permitted to hold spectrum directly or through their partnering service providers. It also noted that decisions on using IMT spectrum for D2D satellite services could await the outcome of the World Radiocommunication Conference in 2027.
Stakeholders have also been asked to provide views on how the relationship between SCN-authorised entities and service providers using their networks should be structured. The paper seeks inputs on how revenues of SCN entities should be defined for calculating adjusted gross revenue (AGR), authorisation fees and spectrum charges. Trai has also sought views on entry fees, minimum equity and net worth requirements, bank guarantee structures, application processing fees and payment terms for spectrum charges.
Stakeholders have been asked to submit written comments by May 6, 2026, and counter-comments by May 20, 2026.
 "telecom, TRAI")