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Nasscom’s Feedback on the Telecommunications (Telecom Cyber Security) Amendment Rules, 2025
Nasscom’s Feedback on the Telecommunications (Telecom Cyber Security) Amendment Rules, 2025

July 29, 2025

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The Department of Telecommunications (DoT) issued Draft Telecommunications (Telecom Cyber Security) Amendment Rules, 2025 on June 24, 2025.

 

Nasscom made a submission stating that we support the Government’s objective of strengthening telecom and digital infrastructure security but believe that more detailed consultation and clarity are essential to ensure proportionate, risk-based, and innovation-friendly regulation.

 

The proposed amendments have wide implications for digital businesses across fintech, e-commerce, OTT, mobility, ed-tech, and logistics, many of which rely on mobile numbers for user verification. The expansive definition of telecom identifiers and the introduction of the Mobile Number Verification (MNV) platform require a thorough impact assessment before implementation.

 

Key Concerns

  • Scope of MNV: The draft lacks clarity on who qualifies as a Telecommunication Identifier User Entity (TIUE), whether all digital platforms using mobile numbers are covered, and whether MNV integration will be mandatory or phased.
  • Operational and cost impact: Details on the verification process are missing, while the proposed INR 1.5–3 per verification fee is 30–60x higher than current OTP costs, posing risks to startups and high-volume platforms.
  • Regulatory overlap: The amendments intersect with RBI, SEBI, IRDAI, DPDP Act, and IT Rules, creating potential duplication and extending beyond the Telecommunications Act’s scope.
  • Objective alignment: The heavy focus on user traceability via telecom identifiers may not directly address the core goal of protecting telecom networks from cyber threats.

 

Our Recommendations

We recommended comprehensive stakeholder consultation, a detailed impact and cost-benefit assessment, and alignment with existing regulatory frameworks before finalising the amendments. Ensuring proportional, risk-based compliance will safeguard networks while supporting innovation and digital inclusion.

 

For more information, kindly write to vertika@nasscom.in or sudipto@nasscom.in with a copy to policy@nasscom.in


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202507_nasscom_response_cybersecurity_rules.pdf

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Vertika Misra
Director - Public Policy

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