The Unified Licence framework under the Indian Telegraph Act 1885 was famously multi-layered. A single UL could carry Unified Access Service, National Long Distance, International Long Distance, ISP Category A, Public Mobile Radio Trunking, VSAT, and other overlays with separate fees, entry conditions and compliance obligations for each. Infrastructure sat separately as Infrastructure Provider Category-I (IP-I) registration and Infrastructure Provider Category-II licence. The whole edifice was administered through contractual licence conditions that could be varied by DoT.
The 2026 authorisation regime replaces that with an 11-box grid: five principal service authorisations governing what services you can provide to end-users, and six network authorisations governing what network infrastructure you can operate. Each box has its own entry conditions, fees, obligations, and 20-year default validity. This lesson walks the grid and maps every operator type to the correct box.
The five principal service authorisations
The Principal Telecom Services Rules 2026 (G.S.R. 513(E) dated 24 June 2026) prescribe five service authorisation categories [L4-C1].
| Authorisation | Scope | Typical holder |
|---|---|---|
| Unified Service Authorisation (USA) | Covers Access Service and Long Distance Service under one authorisation. National scope. | Airtel, Jio, Vi, BSNL (the four large telcos that currently hold Unified Licences with UAS overlay) |
| Access Service Authorisation (ASA) | Voice and data access services to end-users within a defined service area. Successor to the UAS overlay. | Regional telcos, MVNOs applying as VNOs |
| Wireline Access Service Authorisation | Wireline (fibre to the home, DSL, coax) services in a defined area. Successor to the wireline-only UAS variant. | Tata Play Fiber, ACT Fibernet, Hathway, YOU Broadband, small ISPs with fibre plant |
| Internet Service Authorisation (ISA) | Internet access services including via wireless / cable / fibre. Successor to ISP Category A / B / C. | ISP licensees migrating from ISP-A / B / C |
| Long Distance Service Authorisation (LDSA) | National Long Distance and International Long Distance. Successor to NLD and ILD licence categories. | Reliance Jio Infocomm (NLD/ILD), Bharti Airtel (NLD/ILD), Tata Communications (NLD/ILD) |
Each principal service authorisation is valid for 20 years and can be applied for as Network Service Operator (NSO, operating your own network) or Virtual Network Operator (VNO, wholesale-purchase capacity from an NSO and retail to end-users) [L4-C2]. The NSO / VNO choice determines your capital-expenditure profile, your regulatory scrutiny surface, and your commercial flexibility.
The six network authorisations
The Network Authorisation Rules 2026 (notified 20 July 2026) prescribe six network authorisation categories [L4-C3].
| Authorisation | Scope | Annual fee | Typical holder |
|---|---|---|---|
| Infrastructure Provider (IP) | Passive infrastructure: towers, dark fibre, ducts, right of way. Successor to IP-I registration. | Nil | Indus Towers, ATC India, Sterlite Tech, TCL, RailTel |
| Digital Connectivity Infrastructure Provider (DCIP) | In-building solutions, campus Wi-Fi at scale, distributed antenna systems, small-cell densification. | Nil | Frog Cellsat, iBwave India partners, ANH Global, in-building solution integrators |
| Internet Exchange Point (IXP) | Layer 2 peering fabric for interconnection between networks. Public and private IXPs. | Nil | NIXI (National Internet Exchange of India), DE-CIX India, Extreme IX, Mumbai IX |
| Satellite Earth Station Gateway (SESG) | Ground segment for satellite networks: hubs, gateways, feeder links, RF converters. | Nil | Starlink India gateways, Jio-SES gateways, Eutelsat OneWeb India gateways, Nelco (Tata Group) |
| Cloud-hosted Telecom Network (CTN) | Telecom network functions hosted on cloud infrastructure (Open RAN control plane on cloud, 5G core on cloud). | Nil | Cloud providers hosting telecom workloads: AWS India, Azure India, GCP India, Yotta, Sify |
| Mobile Number Portability (MNP) | MNP clearinghouse operations for cross-operator number portability. Divided into two zones covering India. | 1 percent of AGR or 30 percent of applicable entry fee, higher of the two | MNP Interconnection Telecom Solutions (MNP-IT), Syniverse Technologies India |
The annual-fee column is the eye-opener. Only MNP carries an annual authorisation fee under the 2026 Rules. The other five categories charge only entry fees. Compare this to the old regime where every category attracted its own annual licence fee. The revenue design shift is deliberate: DoT is moving revenue collection from annual licence fees on infrastructure operators to the 5 percent of AGR Universal Service Levy under the Digital Bharat Nidhi and to spectrum charges (auction proceeds for Section 4 categories, administrative pricing for Fifth Schedule satcom).
The 11-box grid: mapping every operator type
An operator can hold one principal service authorisation and multiple network authorisations. Or the operator can hold only a principal service authorisation and buy network capacity from IPs. Or only network authorisations if you are pure infrastructure without end-user services.
| Operator | Principal service auth | Network auth(s) |
|---|---|---|
| Reliance Jio Infocomm | Unified Service Authorisation (USA) | Owns IP (dark fibre + towers via Jio-owned Reliance Digital Fibre) + likely SESG (Jio-SES) + CTN (Jio Cloud) |
| Bharti Airtel | Unified Service Authorisation (USA) | Owns IP (Indus Towers stake) + LDSA (NLD/ILD) merged in USA + Nxtra CTN for own cloud |
| Vodafone Idea | USA | Rents IP capacity; may hold DCIP for enterprise |
| BSNL | USA | Owns full IP + DCIP + CTN (BSNL-owned) |
| Tata Play Fiber | Wireline Access Service Authorisation | Rents IP from parent; may hold DCIP for MDU deployments |
| ACT Fibernet | Wireline Access Service Authorisation | Owns some passive infra; may hold IP for that |
| Hathway | Wireline Access Service Authorisation + Internet Service Authorisation | Owns IP (coax plant) + possible DCIP |
| Tata Play (DTH) | Watch Broadcasting Rules 2026 draft (2 Oct 2026 consultation close) | SESG (uplink teleport) + Draft Broadcasting Rules migration path |
| Starlink India | GMPCS via IN-SPACe + likely Access Service Authorisation for direct-to-consumer | SESG (multiple ground stations under construction) |
| Jio-SES | GMPCS via IN-SPACe + wholesale to Jio USA | SESG (Jio-SES gateway) |
| Eutelsat OneWeb | GMPCS via IN-SPACe + wholesale via Bharti Airtel | SESG (Mehsana gateway) |
| Indus Towers | None (pure infrastructure) | IP (national) |
| NIXI | None (peering only) | IXP (national) |
| AWS India / Azure India / GCP India | None (if only hosting third-party telecom workloads) | CTN |
| Yotta / Sify | Internet Service Authorisation (if providing internet access) + CTN | IP (data centres) + CTN |
| MNP-IT (MNP Interconnection Telecom Solutions) | None | MNP (zonal) |
| WhatsApp / Telegram / Signal (OTT communication) | None (not a telecom entity) | None; but TIUE under TCS Amendment 2025 + SIM binding directive addressee |
Read your organisation off the table. If it does not appear, the closest match is usually right. If two boxes are candidates (for example a large ISP that also holds an ILD for corporate customers), you may need two authorisations.
The one row that will surprise you: OTT communication
WhatsApp, Telegram, Signal, Arattai, JioChat, ShareChat, Josh, Snapchat are not currently classified as telecommunication entities under the 2023 Act. The Union Minister for Communications clarified in December 2023 that OTT communication services are not covered under the Telecom Act 2023 [L4-C4]. Subsequent May 2024 statements by the DoT Additional Secretary softened that position to "under inter-ministerial consultation." The Cellular Operators Association of India (COAI) has argued that OTT access services should be subject to the same licensing framework as telecom operators.
Practical position as of 6 September 2026: OTT communication apps do not hold or need a principal service authorisation or a network authorisation. But the 28 November 2025 DoT SIM binding directive under the TCS Amendment Rules 2025 clearly reaches these platforms via the Telecommunication Identifier User Entity (TIUE) category. They are regulated as consumers of telecom identifiers rather than as telecom entities. Module 4 walks the compliance path in detail.
The NSO / VNO choice
Every principal service authorisation can be held as Network Service Operator (NSO) or Virtual Network Operator (VNO). An NSO owns and operates its own network infrastructure. A VNO purchases wholesale capacity from an NSO and retails end-user services.
The choice determines: (a) capital expenditure profile (NSO carries the network capex; VNO carries only the customer-facing platform), (b) regulatory scrutiny surface (NSO is subject to Rule 25(3) data localisation for its network systems; VNO inherits that indirectly through its NSO contract), (c) commercial flexibility (NSO has full control of the roadmap; VNO can move faster on customer experience but is dependent on NSO capacity terms), (d) migration path (holders of UL(VNO) at the end of the Telegraph Act regime can migrate to VNO-flavoured principal service authorisations under the Migration Rules 2026).
Module 2 walks the NSO / VNO choice in detail with a decision matrix. For a first read, the rule of thumb is: if you own physical infrastructure and want to control your roadmap, apply as NSO. If you are a fast-mover retailer of connectivity or communication services with no infrastructure appetite, apply as VNO.
Next: enforcement archetypes and the quarterly compliance calendar
The 11-box grid tells you where you sit. The next lesson tells you what happens if you fall out of the box. Five enforcement archetypes from the 2024 to 2026 window, and the quarterly compliance calendar for a mid-size ISP that keeps you inside.