Overview Of Telecom User Identification Guidelines

On August 17, 2026, the Department of Telecommunications ("DoT") issued Circular no. 3/User Identification/2026 ("2026 Circular") to strengthen enforcement of the existing limits on mobile connections held by individual subscribers. Under the DoT instructions dated August 09, 2012, read with the reverification framework issued on December 07, 2021 ("2021 Instructions"), an individual may hold a maximum of nine mobile connections across all Telecom Service Providers ("TSPs") and Licensed Service Areas ("LSAs"), with a lower limit of six connections in Jammu & Kashmir, Assam and the North-East LSAs.

The 2026 Circular does not alter these numerical limits. Instead, it addresses the practical difficulty faced by TSPs in identifying subscribers who have reached or exceeded the limit across different operators and service areas. It introduces a common verification mechanism through the DoT's Digital Intelligence Platform ("DIP"), using subscriber data uploaded by TSPs and representative subscriber photographs, so that excess connections can be identified and new connections beyond the permitted limit can be prevented. The Circular hence moves the framework from principally post-facto reverification towards a preventive, cross-operator identification process.

KEY PROVISIONS:

1. DIP-Based Identification of Existing Excess Connections:

The DIP will, on a best-effort basis, use subscriber data records uploaded by TSPs to identify and group mobile connections standing in the name of an individual subscriber across TSPs and service areas. These grouped details will be made available to the concerned TSPs. Where a subscriber has already obtained connections beyond the prescribed limit, the TSP is required to take the measures contemplated under the 2021 Instructions so that the subscriber's connections are brought within the permissible threshold.

2. Photo-Based Checks for New Mobile Connections:

From August 23, 2026, the DIP will make available a representative photograph of each subscriber who has already reached the applicable limit, and TSPs are required to download these images on a daily basis. From August 24, 2026, TSPs must put in place appropriate technical and organisational measures to identify a subscriber seeking an additional connection after reaching the limit, inform the subscriber accordingly, and decline issuance of the new connection.

As a transitional measure, the verification may initially be undertaken on a post-facto D+1 basis. However, the identification check must be integrated into the subscriber enrolment and activation process on a real-time basis by November 30, 2026. Until such real-time integration is completed, any connection activated beyond the prescribed limit is required to be immediately suspended until the issue is resolved.

3. Data Workflow and Regulatory Oversight:

Annexure I to the 2026 Circular sets out the subscriber data verification workflow under which TSP subscriber data and images are submitted on D+1, subjected to data pre-processing and quality checks, and grouped for availability through the DIP and Sanchar Saathi. The workflow specifically contemplates rejection handling for subscriber-data errors and missing or deficient images. The respective LSA is designated as the competent authority to determine issues arising from implementation of the 2026 Circular.

IMPLICATIONS:

1. Shift from Subscriber Declarations to Cross-TSP Preventive Verification:

The principal change is not the permitted number of connections, but the manner in which the limit will now be enforced. TSPs can no longer rely primarily on the declaration made by a customer in the Customer Application Form or on subsequent reverification of excess connections. The DIP creates a cross-operator view of connections held by an individual and requires the limit to be checked as part of the activation process. TSPs will therefore need to align subscriber acquisition, KYC and activation systems with DIP outputs and ensure that existing over-limit cases continue to be resolved under the 2021 reverification framework.

2. Technology, Data Quality and Subscriber-Experience Challenges:

The move from daily image downloads and D+1 checks to mandatory real-time integration by November 30, 2026 is likely to require material changes to onboarding systems and exception-management processes. Data mismatches, name changes, outdated or poor-quality photographs and incorrectly grouped connections may lead to false identification or suspension of genuine subscribers. Since the 2026 Circular does not prescribe a specific image-matching technology or matching threshold, TSPs are suggested to maintain robust manual-review and escalation mechanisms, together with audit trails recording the basis on which a connection was declined or suspended. Processing and exchange of subscriber photographs and connection records should also be aligned with applicable telecom user-identification, security and data-protection requirements.

3. Compliance and Enforcement Readiness:

The 2026 Circular introduces a clear activation-control obligation: once a subscriber has reached the prescribed limit, an additional connection cannot be provided, and any excess connection activated during the interim post-facto phase must be suspended immediately. TSPs should therefore establish defined internal ownership for DIP monitoring, daily data and image ingestion, real-time activation controls, exception handling and LSA escalation. This assumes added significance in light of the Telecommunications (User Identification) Rules, 2026, notified shortly thereafter on August 21, 2026, which establish a broader biometric-based identification framework for telecom users. The two frameworks should accordingly be implemented through an integrated subscriber-identification architecture rather than as separate compliance processes.

Please find attached a copy of the 2026 Circular here.