Seeking Inputs: TRAI Pre- Consultation Paper (CP) on Enabling Unbundling of Different Layers Through Differential Licensing

The telecom regulator on 9.12.2019 published a pre-consultation paper on enabling unbundling of different layers (e.g. infrastructure, network, services and application layer) through differential licensing. The unbundling of different layers is also one of the strategy laid down under the National Digital Communication Policy (NDCP) 2018, towards catalysing investments, innovation and ease of doing business .

As per the prevailing regulatory regime, infrastructure, network and services layer are not segregated and are bundled as part of the Unified Licence (UL).  The CP mentions that unbundling of different layers will lead to optimum utilization of telecom resources by sharing of telecom resources, leading to additional revenue generation for owners/ service providers.

The current consultation therefore seeks views on the issues that needs to be considered for enabling unbundling of different layers of telecom services and changes that are needed for facilitating such regime.  Following are the questions on which TRAI has sought comments:

Q1. What could be the possible benefits and anticipated problems in having an unbundled licensing regime? Kindly suggest the measures that can be taken to overcome the anticipated problems (if any).

Q2. In case it is decided to unbundle the different layers of licensing,

(a) what should be the different layers and their scope? What changes would be required in licensing regime to enable such a framework?

(b) Should there be a new regime of licensing on which the existing licensees should migrate within a specified time frame or there should be a parallel incentivized licensing regime for unbundled layers of license?

Q3. In case you are of the opinion that there is no need of unbundling of different layers of the license, what changes should be made in the existing licensing regime to (i) promote sharing to increase utilization of the existing resources, and (ii) catalyse investments and innovation in Digital Communications sector?

Q4. What other reforms / changes are required in the existing licensing regime?

The pre-consultation can be accessed from here

Last date for sending inputs to TRAI is January 6th, 2020. Members are requested to kindly share their inputs with us latest by 27th December 2019 enabling us to make timely submission to Government. Kindly send your inputs to and

We look forward to your response.

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