India Has Evolved into a Data-First Telecom Market, with Voice as a Complementary Service: Private Telcos

2. The low-income group consumers, esp. those living in rural areas or using feature phones, require shorter validity packs so that they can recharge as per their requirements.

3. The existing packs are being offered in only two options of approximately quarterly and yearly validities. These higher validity packs require relatively substantial one-time payment, which may be challenging for such low-income group consumers.

4. Whereas the STVs with Voice, SMS and data are offered with many validity options, Voice and SMS only packs are offered with limited choices.

5. Consumers who do not use data have limited choices available and are placed at a disadvantageous position. This lack of parity goes against the objective of ensuring fair, equal and non-discriminatory choices for all consumers, regardless of their service requirements.

6. The Authority observes that the objective of the Telecom Consumers Protection Regulations is to ensure fair choice and protection for all categories of consumers, including low-income users, consumers in rural areas, non-tech savvy and even elderly persons who primarily require Voice and SMS services and have limited or no need for data services.

7. It has been noted that while Telecom Service Providers offer Special Tariff Vouchers (STVs) with Voice, SMS and Data across multiple validity periods, corresponding options exclusively for Voice and SMS are not always made available for the same validities. As a result, consumers who do not require data are often compelled to purchase bundled packs containing data, leading to avoidable expenditure and limited choice.

8. Absence of choices in the Voice and SMS only STVs corresponding to the validities of bundled STVs dilutes the regulatory intent of consumer choice and disproportionately affects non-data users. Ensuring parity in validity options between bundled STVs and Voice and SMS only STVs is therefore necessary.

9. The proposed amendment seeks to address this issue by mandating that for every unique validity period offered under Special Tariff Vouchers with Voice, SMS and Data (whether with or without value added services), the service provider shall also offer a corresponding Special Tariff Voucher exclusively for Voice and SMS. This approach ensures sufficient validity choices for the consumers vis-à-vis STV with Voice, SMS and data benefits.

10. In view of the past experience, it is felt necessary that the Authority takes proactive steps to ensure that the Voice and SMS only packs are priced with reduction largely proportional with respect to the corresponding validity of STV with Voice, SMS and data, so that it remains affordable to the consumers. The price of Voice and SMS only STVs needs to be fixed in a fair and reasonable manner. Since these packs do not include data and only offer the benefits of Voice and SMS, their price should be reduced to the extent proportionate to reduction of data from their corresponding bundled services that offer Voice, SMS and data (with or without value added services).

Private Telecom Operators’ Responses

Below are some of the key comments submitted by the respective telecom operators in response to TRAI’s draft consultation.

Bharti Airtel

1. Airtel strongly submits that the proposed mandates requiring the following should be withdrawn.

a. the provisioning of Voice+SMS-only packs corresponding to every validity of existing bundled offers, and
b. the application of “largely proportgonal” tariff reductgons for such packs/

2. Tariff forbearance and pricing flexibility should remain the cornerstone of telecom tariff regulation in India, as they have been for the past two decades. Within this framework, the Authority’s focus should not be on micro-designing tariff components or prescribing internal price relatgonships within bundled plans. Such an approach will protect consumer interests, sustain competgtgve intensity and enable the contgnued investment necessary for India’s 5G, convergence and future 6G journey.

3. Data is no longer a luxury; it is the default “pipe” through which India’s public and private digital ecosystems reach the common citizen.

4. This mobile-first design is not a convenience, but a necessity in a country where fixed broadband penetration remains limited. Over 95 percent of rural internet users rely exclusively on mobile networks, so any degradation in mobile data access translates directly into reduced access to state services and economic opportunity. Telecom networks have thus become co-equal pillars of governance infrastructure, comparable in importance to roads or electricity.

5. In all these scenarios, Digital Public Infrastructure (DPI) remains inclusive only if every citizen’s telecom pack includes at least some data, even for users who consider themselves “voice-centric.” If regulatory interventions make it economically attractive to shift to pure Voice+SMS-only packs with zero data in exchange for modest savings, many price-sensitive users will rationally down-trade—opting out of data, and therefore out of DPI. Such a step can drive such downgrades among low-income users, creating a structurally “data-excluded” segment and re-introducing a digital divide that India has spent years closing.

6. On one band, the Government is trying to bring more people under digital economy and on the other hand, TRAI is trying to promote zero data tariff plans.

7. TRAI’s proposals—mandating Voice+SMS-only STVs at every validity and linking their pricing proportionally to bundled packs—must therefore be viewed not as narrow tariff tweaks, but as choices that will shape the trajectory of India’s digital state and digital economy. India’s success has come from treating data as a default component of connectivity. A framework that formalizes and privileges data-less connectivity risks reversing that success for the most low-income users.

8. Therefore, a forward-looking policy approach should instead recognize mobile data as a quasi-essential service and ensure that even the lowest-priced plans include a minimum assured data entitlement. This preserves affordability, sustains demand for digital services and reinforces the foundational role of telecom networks in India’s inclusive growth story.

9. Over the last two decades, retail tariffs in India have evolved from high, voice/SMS-only, per-minute pricing to simple “all-in-one” bundles. This transition has been driven by large-scale 4G rollouts, strong competition and a policy approach anchored in tariff forbearance rather than granular, ex-ante price-setting. India has now become a data-first market with affordable per-GB prices, with bundled prepaid packs (voice + SMS + data) forming the default mode of participation. Average monthly usage is now approximately 27–30 GB per wireless user.

10. The premise that entry-level Voice+SMS options are absent is misplaced. The widely available INR 199 prepaid pack (28-day validity) already operates, in substance, as a voice- and SMS-centric plan. The bundled around 2 GB for the entire validity—equivalent to roughly 70–75 MB per day—is purely incidental and not positioned as a value-bearing component of the plan. It is neither sufficient for meaningful data consumption nor priced as a data entitlement, serving only to maintain continuity of essential, low-bandwidth services such as UPI, DigiLocker, UMANG, and other critical digital applications.

11. Accordingly, this minimal data layer does not alter the fundamental character or pricing logic of the plan as a voice-led offering. It simply ensures baseline digital access without constituting a distinct source of consumer value. Therefore, excluding such incidental data cannot be construed as creating any headroom for proportionate tariff reduction. Any such interpretation—whether for this plan or others—would compel operators to rework their entire tariff architecture.

12. This demonstrates that low-value “pure telecom” needs are already being effectively met through voice-dominant bundles with only a nominal data lifeline. Therefore, Airtel strongly submits that mandating a separate Voice+SMS-only tariff grid—particularly with an expectation of lower pricing—is unnecessary. More importantly, it risks inducing down-trading to zero-data products, potentially disconnecting users from essential digital services and undermining the broader objectives of digital and financial inclusion.

13. The value transfer to consumers enabled by non-proportional pricing has been substantial. By way of illustration, a value pack priced at Rs 199 in 2011 would, after applying a modest average annual inflation of 5.5 per cent, correspond to roughly Rs 469 in 2026, yet today Rs 199 typically buys unlimited local and STD calls, free national roaming and additional data (e.g. 2 GB). Such outcomes have been possible precisely because tariffs are not constrained by rigid internal proportionality, allowing operators to enhance value, build loyalty and deliver a genuine win-win for consumers and the sector.

14. Operators need to continuously fund spectrum, dense radio networks, backhaul, core upgrades, IT systems, and substantial operating expenditure. Indian ARPUs remain modest despite very high data usage, leaving very limited room for regulatory compression of revenues. The sector cannot be governed through mechanical cost-plus logic or mandated price symmetry between distinct tariff constructs.

15. A requirement that Voice+SMS-only STVs be proportionally cheaper than bundled plans would reduce revenue without reducing underlying network cost. It would encourage down-trading, weaken portfolio monetization, and directly erode the economic basis for investment in capacity, coverage, and service quality.

16. Airtel respectfully submits that the concern is factually misplaced. Consumers already have access to an affordable entry-level pack of around Rs 199 with 28-day validity. This pack is primarily voice and SMS-led, with only a nominal 2 GB data allocation meant for essential services such as UPI, OTPs and basic apps. It already serves the needs of price-sensitive users requiring low-cost connectivity.

Reference: Airtel’s Entry-Level Unlimited Plan Now Starts at Rs 199

Reliance Jio Infocomm

1. While the intent of enhancing consumer choice seems pro-consumer, it is respectfully submitted that such a mandate may lead to unintended consumer inconvenience. Going by the prevailing validity periods of STVs on offer, this amendment is proposing to expand number of exclusive voice and SMS STVs from current 1-2 to 8-12 for a TSP. We regret to highlight that this mandate seems to have been proposed without analyzing the success of the previous mandate and without any publicly available empirical data to support this proposal.

2. We submit that instead of benefitting the consumers, this proposed measure will further complicate the life for telecom consumer who will buy a voice/SMS only pack lured by its lower cost for his/her preferred validity and then will find out to their shock that he cannot even make:

• UPI payments
• Online recharge
• Access and leverage the benefits of self-care app.
• Communication via OTT apps
• Access to social media and other entertainment,

As all of the above needs data connectivity. This could lead to inconvenience, additional expenditure, and dependency on external assistance, particularly affecting elderly, and rural users.

3. On this unpleasant realization, the customer will have to take help for online data pack recharge or run to nearest retail store for the same, as the life is intricately interlinked with data and data is imperative to use these modern technology features for everyone. For another set of customers this cycle will be preceded by query to customer care, complaints to the Authority and followed by an inevitable purchase of a data pack to offset the mistake of buying this cheaper looking TRAI mandatory recharge. We submit that this is just a reproduction of event cycle that has become apparent from the thousands of queries received at various touchpoints for the currently available NO DATA packs. Pertinently many of these are elderly customers that are seeking some data for at least UPI payments with these exclusively voice/SMS recharges and many more are rural users.

4. We submit that the tariff plans offered by RJIL are completely aligned to meet the requirements of entire spectrum of the customer preferences and usage patterns. RJIL has a very active customer service and feedback mechanism. We are interacting with customers while serving them at call centres, through Interactive BOTs, our website and self-care application, through physical stores located across the country and through home visits by our agents to deliver SIMs or to address service queries and issues.

5. This enables us to decipher consumer choices and design products to match the consumer requirements. This understanding has shaped the entire bouquet of tariffs on offer. The tariffs being offered meet the requirement of all users e.g.

a. An unlimited 4G data plan for regular heavy data users.
b. An unlimited data pack with 1 day data validity for occasional heavy data users.
c. Tariff offers providing daily data entitlements of 1 GB/1.5 GB/2 GB/2.5 GB/3 GB with validity ranging from 18-22 days to 84-98 days.
d. PV, CV and STV with monthly i.e., 30 days validity and those that can be renewed on same date every month.
e. Annual tariffs with heavy data as well as low data allowance.
f. A voice centric low cost 28 days validity tariff offer that provides unlimited voice calls with only 2 GB of monthly data allocation.
g. Special data boosters for all kind of intermittent data requirements.
h. Very low entry level as well as regular tariff for customers with low paying capacity and using smart feature phones.
i. Exclusive Voice and SMS benefits STVs with the validity period of 84 days and 336 days. (As mandated by the Authority vide 12th Amendment)

6. Further, we do not agree with the assumption that elderly or rural based customers do not require data with their plans. We submit smartphone usage and data usage can be seed in every age group and region in the country. The smartphone users exceed 1000 million already with projections of exceeding 1500 million by 2040. Over 76% of Indian wireless users are broadband users, as evident from TRAI’s own data.

7. We reiterate our submissions made earlier also that a vast number of consumers in age above 65 years like to use mobile data services as this enables them in hassle-free daily shopping with help of UPI, staying connected over social media groups, ordering daily needs including medicines on e-commerce / quick commerce platforms and for using video on demand. Thus, evidently, there is no need to mandate tariffs to address unfounded issues for this classify this age group any differently in India.

8. Similarly, the consumers in the rural areas are seeking more and more data which can help them connect with the world. We constantly get queries from rural areas on timelines for 5G availability in their areas, wherever 5G is currently not available and this surely does not pertain to voice/SMS only packs.

9. The current data clearly challenges the premise that there is meaningful standalone demand for voice only plans, as detailed below:

a. 40–45% of subscribers on voice-only plans are still purchasing data add-ons, indicating that even this segment is not purely voice-centric. The remaining 55–60% are also using some data.
b. Any voice only customer using any amount of data is an informed data customer who is buying data in spite of buying voice only plan. The number of customers buying voice only plan and then sticking to same are very small.
c. Among users on the Rs 189 entry-level bundled low data plan with only 2 GB data, 88% users actively consume data at significant levels.

10. The above data points lead to a fundamental question: If even the lowest-paying users and so-called “voice-only” subscribers are consistently using data and the consumer buying voice only plan are also buying add-on data, where is the real demand for pure voice-only services?

Evidently, the evidence suggests:

a. Data usage is now near-universal, even among price-sensitive segments.
b. There are no Voice-only customers.
c. The market has effectively evolved into a data-first ecosystem, with voice as a complementary service.

11. Thus, we submit that it will not be in consumer interest to confuse them with a lower cost recharge that will deprive them of data benefits. India has the world’s lowest data tariffs and service providers offer tariffs with varied data quotas starting with 2 GB per month upto 3 GB per day and even unlimited 4G and 5G data. The availability of these tariffs, without any doubt, has led to India’s digital growth and TRAI is requested to not disturb the same.

12. We submit that as per our internal data analysis, the voice/SMS only plans and lower MRP plans are the preferred option of spammers. The following data points, collated basis AI-ML suspected plan flagging are pertinent for the Authority’s consideration.

a. The percentage of spammers vis-à-vis subscribers on a STV is much higher on voice/SMS only STVs with MRP Rs 448 and Rs 1748 in comparison to other packs. For instance, it is 2.5 times that on popular daily data plan 299.
b. The percentage of spammers vis-à-vis subscribers on a STV is highest on the lowest entry level STV of Rs 189, viz. 3.6 times that on popular daily data plan 299.

These data points clearly point to the trend that the introduction of lower price points with low data or zero data, will be a boon for spammers and their adoption of these plans is likely to increase.

13. It is also quite possible that these spammers are the ones that are pushing the narrative that there is a need for lower cost and lower validity for the voice/SMS only recharges. The Authority should be aware of these negative fallbacks before even contemplating such proposals.

14. Furthermore, it needs to be borne in mind that post the debunking of ‘first come first serve’ policy by Hon’ble Supreme Court in the landmark 2G judgement in 2012, all spectrum in the country is assigned through auction. The TSPs have been acquiring the right to use spectrum at very high costs, with an implicit understanding of prevailing policy of tariff forbearance. However, the Authority has, of late, intervened multiple times in tariffs, which has effectively vitiated the auction terms and conditions, causing the investors to rethink their investment viability. We submit such interventions should be avoided and the market forces should be allowed to function smoothly, as this is the only way the sector can prosper as more investments in newer data technologies will flow.

15. Data services are required for even the least data savvy customers to at least use the UPI, which is the most preferred payment instrument in the country right now and also experience the transformative changes being ushered by Artificial Intelligence (AI) and generative AI apps. Further, the Government under its Digital India mission and Viksit Bharat vision is heavily relying on data services to deliver the Government services, scheme benefits to the consumers. The consumers are also using data services for their critical daily need services like mobile recharge, train and bus ticket booking, electricity, water and gas bill payment, downloading boarding pass and using applications like Digi-Yatra. Thus, a world without data services is unimaginable, at least in India. Consequently, mandating multiples of voice/SMS only plan will be a huge travesty to data centric world and would confuse and deprive the exact segment it is targeted at i.e. the elderly and rural users, as they will be more susceptible.

16. It is also worthwhile to mention here that Unlimited voice services is an important generational change in telecom tariffs in India. RJIL introduced these beneficial innovations to post extensive study of international examples of flat tariffs and simplified charges for voice services. Unlimited voice in both home and roaming has unburdened the consumers from continuous ongoing recharges and gone are the days when the customers would need expensive roaming packs or search for PCOs to make important calls while travelling. The impact of these innovations is seen in the increased MOUs and the fact that such tariffs have now become the norm across industry. Therefore, no curbs should be put on such innovations by TSPs under current Forbearance regime by mandating the tariffs. It is submitted that any move to impact the unlimited voice benefits will be a retrograde step against the national vision and policy documents like NDCP-2018.

17. Conclusions

• The current tariff plans are aligned with consumer choices and there is no scope for intervention.
• There is no need to mandate more voice/SMS only plans for each validity period and the current plans are sufficient to meet the requirements.

Vodafone Idea (Vi)

Vodafone Idea started its response by highlighting the importance of internet access and the Digital India programme.

1. The Digital India Program was launched by Hon’ble Prime Minister of India on 1 st July 2015, with the vision to transform India into a digitally empowered society and knowledge economy.

2. The Digital India initiative is formed on the bedrock of a key pillar i.e. digital connectivity. The broadband subscribers have grown from 10.49 crs at the end of May’2015 to 106.58 crs at the end of March’2026, with average monthly wireless data consumption rising to 25.7 GB per user in quarter ending Dec’2026. This demonstrates the centrality of internet access in everyday life.

3. For continued success in uptake of the policies and schemes under Digital India Initiative, it is important to further encourage and incentivize consumers for becoming more Digital literate instead of nudging them to not use data. For rural consumers who may not be able to change the handset due to upfront costs, it should be recommended to the Government to come out with handset subsidies, through their TSPs, for the rural customers to migrate to smartphones. Digital literacy programs should continue to be carried out so that the policy objectives of the Digital India initiatives can be fully achieved.

4. Affordability continues to be the main pillar of present Tariffs in the market:

a. The Indian telecom sector continues to offer one of the most affordable tariff regimes globally, a fact that has been consistently underscored by the Government. The Hon’ble Minister for Communications has also highlighted recently availability of affordable voice and data tariffs, which are among the lowest globally, and underscored India’s success in building Digital Public Infrastructure (DPI).

b. This affordability is reflected in persistently low ARPU levels in India—among the lowest globally—even as operators continue to invest heavily in network expansion and next-generation technologies. The success of India’s telecom model is anchored in a “low-cost, high-volume” approach, which has enabled widespread access and rapid scale across the country.

c. At the same time, India has emerged as one of the largest consumers of mobile data worldwide, with exponential growth in per capita data usage driven by affordable pricing and bundled offerings. This unique combination of ultra-low tariffs, low ARPU, and very high data consumption has been made possible primarily due to the flexibility available to telecom service providers (TSPs) to design innovative and consumer-centric tariff structures, including bundled voice, SMS, and data packs.

5. No deprivation of low-income consumers; rather, provision of enhanced value: Contrary to the assertion, low-income consumers are not being deprived of affordable options. Instead, they are being offered tariff packs that deliver enhanced value. The inclusion of a small data component within entry-level packs does not materially increase the price, but significantly enhances the utility of the service by enabling access to essential digital services, thereby improving overall consumer welfare.

6. Tariff structure driven by cost of maintaining network connectivity, not data provisioning: It is important to note that the primary cost driver for telecom service providers (TSPs) in offering entry-level plans is the cost associated with maintaining an active and connected subscriber on the network — covering spectrum usage, network infrastructure, signaling, and fixed operational overheads. The incremental cost of provisioning a small amount of data is relatively negligible in comparison. Therefore, the presence or absence of data in such packs does not materially alter the underlying tariff, and removing data would not translate into any meaningful reduction in prices for consumers.

7. Bundled data ensures critical connectivity, including in emergency situations: The inclusion of minimal data in entry-level packs plays a crucial role in ensuring that consumers remain digitally connected at all times. In emergency scenarios—such as medical exigencies, accidents, or personal safety situations — data-enabled services (e.g., live location sharing through applications like or navigation support can be vital and, in some cases, life-saving. A regulatory approach that defaults users to voice-only connectivity may inadvertently expose them to avoidable risks by limiting access to such critical functionalities and by nudging towards non-data packs.

8. Regulatory prescription may undermine consumer interest and market efficiency: Mandating the provision of Voice and SMS-only packs across all validity options could constrain tariff flexibility, reduce the ability of TSPs to optimise offerings, and potentially lead to unintended consequences such as reduced value for consumers. The existing forbearance regime has demonstrably delivered affordable tariffs, high data consumption, and widespread digital inclusion, and should therefore be preserved in the interest of both consumers and sectoral sustainability.

9. Bundled plans do not disadvantage consumers; rather, they act as a safety net: The inclusion of a minimal data component in tariff packs should not be viewed as discriminatory or disadvantageous to voice-centric users. On the contrary, such bundling acts as a built-in safety net, ensuring that all consumers—irrespective of their primary usage preference—retain a baseline level of digital connectivity, which is increasingly essential in today’s ecosystem.

10. Protection against unintended data usage and high pay-as-you-go charges: In practical scenarios, even consumers who do not actively use data may inadvertently trigger data consumption due to automatic system updates, background application activity, or device-level processes. In the absence of an in-built data allowance, such usage would be billed on a pay-as-you-go basis, often at significantly higher rates, thereby exposing consumers to avoidable financial burden.

11. The present tariff structure promotes fair, equal and non-discriminatory choices for all the segments of the society.

Reference: Vi’s Over 100 Prepaid Tariff Plans in 2025 

12. Voice + SMS only packs across each such validity as is for Voice+SMS+Data may increase number of tariff packs causing confusions and would not be consumer-friendly.

Further, mandating the introduction of separate voice and SMS-only packs across each validity tier where bundled voice, SMS, and data packs already exist would lead to a proliferation of tariff options, thereby increasing complexity and potentially causing consumer confusion.

13. Such an approach runs counter to the objective of simplification, as it would result in a crowded tariff landscape with multiple near-identical offerings differentiated only by the presence or absence of minimal data. For consumers—particularly those in low-income or rural segments—this may lead to decision fatigue, lack of clarity, and sub-optimal plan selection, ultimately undermining informed choice rather than enhancing it.

14. The current market-driven approach, which allows telecom service providers to curate a balanced and streamlined set of offerings, ensures ease of understanding and better consumer experience. Therefore, a prescriptive requirement to mirror every bundled pack with a standalone variant risk making the tariff ecosystem more cumbersome and fragmented, instead of simple and consumer-friendly.

The END.

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