Broadband India Forum urges DoT to review its new cyber security, SIM binding rules

Mumbai: Tech industry body Broadband India Forum (BIF) has urged the Department of Telecommunications (DoT) to review its recently introduced Telecommunications (Telecom Cyber Security) Amendment Rules, 2025, and a related SIM Binding Directive, warning that the new framework contains legal flaws and overreaches the boundaries of the existing Telecommunications Act, 2023.

The SIM binding mandate comes into effect from March 1, which means apps such as WhatsApp, Signal, etc will only function when the registered SIM card is physically present and active in the device.

The views submitted by BIF are based on a legal opinion obtained by the body from an unnamed Senior Counsel.


As per the legal opinion, the directive's introduction of a new category of regulated entities called Telecommunication Identifier User Entities (TIUEs) that are businesses that use telecom identifiers such as mobile numbers, IP addresses, or IMEIs to identify users or deliver services. The category covers a broad range of companies, from banks and fintech platforms like Paytm to communication apps like WhatsApp. Under the SIM Binding Directive issued on 28 November 2025, TIUEs are required to comply with government orders blocking fraudulent identifiers, meet data protection obligations, participate in Mobile Number Verification (MNV), and cooperate with law enforcement.

As per BIF, it is unlawful as unlike licensed telecom operators, TIUEs are not authorised entities under the Telecommunications Act, and merely using a phone number within an app does not amount to "telecom use" as the law defines it.

"Extending telecom rulemaking to digital platforms through delegated legislation risks duplication, jurisdictional conflict, and inconsistent compliance burdens across sectors," it said.

BIF has called for an urgent review and a more collaborative approach to building an anti-fraud framework that is legally sound, operationally clear, and capable of earning business and public trust.