Telecom licence migration is the process through which existing telecom licence holders transition from previous licensing regime to new authorisation regime. Existing telecom companies can continue operating under their current licenses until they expire. As per the DoT migration framework, applications for migration of licences with a definite validity period are generally required to be filed at least 12 months prior to license expiry subject to applicable rules and exceptions.
However, if a licensee wishes to shift to the new framework before expiry to expand scope of services, it may apply for migration subject to approval of Department of Telecommunications. For assistance in telecom migration process, you can get in touch with our experienced telecom consultants at Registrationwala.
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Migration of telecom licence is the process of transitioning from old telecom licensing system to new authorisation system. This process allows eligible telecom licensees to replace their existing licence with appropriate authorisation and continue providing telecom services under the newly established authorization based system. The application for telecom license migration must be filed online with Department of Telecommunications via Telecom eServices Portal.
The application for telecom license transfer must be submitted at least 12 months prior to expiry of existing licence. This means that if a telecom licence is going to expire on 31st of December 2027, the migration application should be submitted on or before 31st of December 2026. Migrating a telecom license involves a number of legal, technical and procedural requirements that can be pretty difficult to manage for the licensee.
Just as a ship needs an experienced captain to sail safely, you need expert guidance to complete the telecom license migration process promptly. At Registrationwala, we can help you complete your migration process quite smoothly and with confidence.
There is no obligation to migrate the telecom licence on an immediate basis but companies can choose to migrate for the following reasons:-
To provide new services:- When a company wants to offer a new telecom service that it doesn't currently offer to customers, it must first move to the new authorisation framework.
After Licence Expiry:- The company has to obtain the relevant authorisation to continue providing telecom services to customers when the existing telecom licence expires.
Lower compliance costs:- The new framework has a single bank guarantee in place of multiple guarantees. This makes compliance a lot simpler and cost effective.
The timeline for filing an application for telecom license migration is as follows:
|
Situation |
Application Timeline |
|
Where licence has a defined expiry date (general rule) |
Application must be filed at least 12 months before expiry |
|
Licence has less than 12 months validity remaining (at the time of notification of migration rules) |
In such a case, application must be filed within 90 days of notification OR before expiry, whichever is earlier |
|
Licence without fixed validity |
Application must be filed at least 12 months before the 5-year reference period ends |
Companies holding telecom licences such as Unified Licence (UL), UASL, ISP licence or other service-specific telecom licences, which are still active and not expired, can apply for license migration if they:-
Possess a valid telecom licence/registration/permission eligible for migration.
Meet eligibility criteria for corresponding authorisation under new framework.
Satisfy migration conditions as well as requirements as specified by DoT.
Submit the migration application via Telecom eServices Portal within the prescribed time.
The following documents are required for migration of telecom license:-
Certified copy of Board Resolution on applicant's letterhead authorizing the submission of the application by the applicant.
Certified copy of Board Resolution on applicant's letterhead authorizing the person signing the application to act as authorized signatory for application submission and all related matters.
A Power of Attorney in favor of authorized signatory.
A certified copy of the appointment letter for auditor issued by Board of Directors along with an acceptance letter from auditor.
Certified Copy of Certificate of Incorporation along Articles of Association and Memorandum of Association. The Memorandum of Association must include Telecommunication Services as one of its main objectives.
A certificate indicating the net worth of applicant.
A certificate confirming paid-up equity capital of the applicant.
A certificate detailing breakdown of paid up equity capital into Indian and foreign equity, along with further details on breakdown of foreign equity.
A certificate certifying that any foreign direct investment (including from countries sharing a land border with India) in applicant complies with policies issued by the Government of India regarding foreign direct investment, where applicable.
A certificate that confirms that applicant meets eligibility criteria under Rule 5 of Telecom Authorisation Rules 2026.
The telecom license migration process involves the following steps:-
Step 1:- Checking Eligibility and Preparing Documents
The telecom licensee must first ensure they fulfill eligibility conditions and requirements prescribed by DoT for the purpose of telecom licence migration. After that, the licensee must prepare all the documents required for the telecommunication license migration application.
Step 2:- Filling Out the Migration Application Online
Next, the licensee must fill out the migration application form online via designated portal, i.e., the Telecom eServices Portal. All the required details must be entered and the necessary documents must be uploaded.
Step 3:- Uploading the Digitally Signed Application Form
After completing the application form, the licensee must digitally sign it by using a valid Digital Signature Certificate and then upload the form on the portal.
Step 4:- Scrutiny of Application by DoT
After that, the Department of Telecommunications carefully reviews the application and supporting documents so as to verify applicant's eligibility and ensure that the application is in compliance with migration rules.
Step 5:- Approval of Migration Request
If application receives approval, the migration request is reflected under Migration Requests section of designated portal. The corresponding authorised telecom services are then shown as migrated and operational under new authorisation framework.
Step 6: Payment of Applicable Fees
No additional entry fee is charged for basic migration from existing licence to corresponding authorisation. However, the applicable non refundable processing fee for telecom migration remains payable.
It is important to note that if the applicant seeks to expand the scope of its services or service areas beyond migrated authorisation, the applicable entry fee and other prescribed charges also need to be paid.
Registrationwala has been assisting businesses with telecom registration and post registration compliance for more than a decade now. We have a dedicated team of experienced chartered accountants, company secretaries, lawyers and other highly qualified professionals who are well versed in telecom processes.
The new telecom migration rules may seem daunting for businesses that are unfamiliar with the latest regulatory framework or are unsure about the migration requirements. However, our experienced team can make the entire process seem like a cakewalk by handling every step on your behalf.
Here is how we can assist you:
Assessing Your Eligibility
Preparing Required Documents For Migration
Filing Migration Application On Your Behalf
Providing Complete Post-migration Compliance Support
Q1. What exactly is telecom license migration?
A. It refers to the process whereby an existing telecom licensee migrates from old licensing framework to new authorisation framework.
Q2. What is the telecom licence migration fee?
A. The applicable non-refundable processing fee depends on the authorisation the licensee is migrating to. To know exact processing fee applicable in your case, you can connect with our telecom consultants.
Q3. When should a telecom licensee file the application for the migration of telecom licence?
A. A telecom licensee should file the application for telecom licence migration at least 12 months before existing licence’s expiry. A licensee may also apply for migration even earlier than this if it wishes to expand the scope of its telecom services under the newly introduced authorisation framework.
Q4. Which rules govern the migration of telecom licenses?
A. Telecommunications Terms and Conditions for Migration Rules 2026 govern the migration of telecom licenses.
Q5. Can existing telecom licensees continue to operate under their licenses?
A. Yes. Existing telecom licensees can continue operating under their current licences until the licences expire subject to compliance with existing terms as well as conditions. However, once a licence is nearing expiry, it cannot simply be renewed under old licensing regime. So, to continue providing telecom services after its expiry, the licensee must migrate to corresponding authorisation. The telecom license transition application must be submitted at least 12 months before the licence expires. With that being said, a licensee may choose to migrate even earlier so as to expand scope of services under new framework.
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