The Department of Telecommunications (DoT) has issued directions to app-based communication service providers to make it impossible for their users to use services without a SIM. This comes after the DoT notified the Telecommunication Cybersecurity Amendment Rules, 2025, which bring in the category of telecommunication identifier user entity (TIUE) under the scope of telecom regulations. The amendment introduced a new category of service provider called the Telecommunication Identifier User Entity (TIUE), which would fulfill a range of cybersecurity obligations, including using a Mobile Number Validation (MNV) Platform to verify the customers or users associated with a telecommunication identifier for services linked to such an identifier. Besides validation, the government can also direct TIUEs to stop using a specific telecom identifier to identify customers or deliver services.

As soon as the rules were first introduced, many had raised concerns that the TIUE category was extremely broad and would include virtually any business that collects customer phone numbers to provide a service. Anything from a food delivery service like Swiggy or Zomato to a local grocery store that sends it customers e-receipts by collecting mobile numbers would fall within its scope.

These new directions, which the government has sent to WhatsApp, Telegram, Signal, Arattai, Snapchat, ShareChat, Jiochat, and Josh, effectively recognise these companies as TIUEs. They direct them to ensure that SIM cards are continuously linked to their services within the next 90 days. Further, for website/web-app based access, the TIUEs must ensure that the user gets logged out periodically (not later than 6 hours). They must provide users an option to re-link their account using a QR code-based service.

Full text of the directions:

  1. WHEREAS, the Department of Telecommunications (DoT) has, vide Notification No. CG-DL-E-21112024-258808 dated 21st November, 2024, notified the Telecommunications (Telecom Cyber Security) Rules, 2024, and has subsequently amended the same vide Notification No. CG-DL-E-22102025-267074 dated 22nd October, 2025 (hereinafter collectively referred to as “the Rules”);
  2. AND WHEREAS, Rule 2(i) of the Rules defines “Telecommunication Identifier User Entity (TIUE)” to mean a person, other than a licensee or authorised entity, which uses telecommunication identifiers for the identification of its customers or users, or for provisioning or delivery of services.
  3. AND WHEREAS, Rule 4(3) of the Rules obligates every telecommunication entity and TIUE to ensure compliance with the directions and standards, including timelines for their implementation, as may be issued by the Central Government for the prevention of misuse of telecommunication identifiers or telecommunication equipment, network, or services for ensuring telecom cyber security
  4. AND WHEREAS, Rule 10(2) of the Rules permits the Central Government to use secure modes of…

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Last Update: November 29, 2025