Who owns the network between phone and orbit
Published 11 October 2026
TRAI's April 8 consultation brought the network-authorization question into a detailed public process. It asked about eligibility, operating area, duration and the conditions under which a Satellite Communication Network entity could establish and run its system. It also asked who could buy that network as a service, including whether virtual network operators should be eligible. The proposed arrangement separated the company operating the underlying network from the provider serving the customer. That separation could make a satellite system available to several service providers rather than require each to build one. The consultation sought views on the rules needed for such a structure. Its questions were proposals for discussion, not permissions already granted to applicants. trai.gov.in, Consultation Paper on the Framework for Satellite Communication Network Authorisation,... trai.gov.in, TRAI consultation paper, April 2026
One question concerned control of the baseband system. Should the network operator be required to give its partnering service provider visibility, control, resource allocation and management on agreed terms? Another asked whether a reference agreement should be mandatory. These were questions about where power inside a commercial partnership would sit. A retailer or service provider could own the customer relationship while relying on another company for the actual satellite network. Without clarity about that relationship, the customer's provider might have obligations it could not fully manage through its own equipment. The consultation put those concerns into the authorization debate without assuming that one agreement could fit every technical and commercial combination. trai.gov.in, TRAI consultation paper, April 2026
The paper also opened the question of direct-to-device service. It listed fixed satellite service, mobile satellite service and direct-to-device links using either satellite-mobile bands or spectrum used by terrestrial mobile systems. It asked whether the last category should proceed immediately or wait for the 2027 World Radiocommunication Conference. This was a different capability from broadband delivered through a household dish and router. The regulatory issues would also differ because a service using an existing mobile band's frequencies would need to coexist with the providers already holding rights to them. The consultation's four categories prevented every possible satellite connection from being treated as the same consumer product under one label. trai.gov.in, TRAI consultation paper, April 2026
Spectrum could be held in several combinations. The network operator could hold both feeder-link and user-link rights, the partnering service provider could hold both, or the two could split the roles. TRAI asked which arrangements should be allowed and whether its earlier assignment recommendations should apply to the new network category with changes. That flexibility carried practical questions. The party operating a spacecraft-linked system needed reliable access to radio rights, while the party serving customers needed an arrangement compatible with its own authorization. A contract between them could not create spectrum permission neither held. The consultation therefore connected commercial structure with the legal rights needed for each link in the system. trai.gov.in, TRAI consultation paper, April 2026 egazette.gov.in, Gazette of India notification, December 24, 2023
The April consultation's financial questions followed the separation of network and service roles. It asked whether payments from a service provider to the satellite-network operator should be deducted when calculating adjusted gross revenue for licence and spectrum charges. Without a clear treatment, the same flow of money could affect charges at more than one level of the arrangement. The paper also asked for definitions of gross revenue, applicable gross revenue and adjusted gross revenue for the new network category. Those terms were not interchangeable labels. Their boundaries would decide which income and deductions entered the calculation. A percentage rate could sound settled while its financial base remained a consequential policy question. trai.gov.in, TRAI consultation paper, April 2026
Other questions covered minimum equity and net worth, entry fees, authorization fees and bank guarantees. These conditions concerned an entity's ability to enter and sustain the business, beyond its access to spectrum. The distinction matters because a low spectrum percentage does not describe the whole financial burden of authorization. Conversely, a company with enough capital to build a constellation does not automatically meet every security or operating condition. TRAI was asking how to set the requirements for a network business that could sell access to service providers. Its consultation opened those issues to argument rather than declaring the new category complete. The paper's detailed questions should not be read as enacted conditions merely because they named possible fees. trai.gov.in, TRAI consultation paper, April 2026
Starlink submitted its response on May 13. It wanted conditions comparable to those attached to the underlying service authorization and argued that existing service-authorized entities or Unified Licence holders should be allowed to extend use of their satellite facilities without another set of network conditions or fees. Its position emphasized avoiding duplication. A provider that already had the necessary infrastructure and service permissions should not, in its view, be burdened again simply because another authorized entity would use those facilities. It did not establish an exemption in law, but it showed the operating model Starlink wanted the new framework to accommodate. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for...
Starlink opposed a compulsory transfer of control or visibility over its baseband system to a partnering provider. It wanted those questions settled by agreement to the extent the parties judged technically and economically appropriate. It also opposed a mandated reference agreement, arguing that diverse designs, commercial goals and integration methods needed flexibility. The response exposed the limits of the March distribution partnerships as evidence of domestic control. An agreement to sell Starlink equipment did not mean the Indian partner controlled the network. In this consultation, Starlink was explicitly resisting a rule that would prescribe that transfer. The commercial partners could negotiate, but the company did not want the authorization itself to force the result. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for... ril.com, JIO TO BRING SPACEX'S STARLINK HIGH-SPEED INTERNET TO ITS CUSTOMERS bharti.com, Bharti Enterprises, 2025-03-11
The company supported all four service categories and wanted direct-to-device use of terrestrial-mobile spectrum allowed without waiting for the 2027 conference. It cited existing country authorizations and said its Direct to Cell operations had caused no harmful interference in more than two years. That was Starlink's performance claim in support of its recommendation. It was not an independent Indian interference test or an Indian authorization for such a service. The distinction matters because a global operating record can inform a regulator without automatically answering the conditions in another market. Starlink was asking India to use existing frameworks and partnership arrangements to move faster while international studies continued. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for...
Starlink wanted all four combinations of feeder-link and user-link spectrum ownership permitted. Either the network entity or its service partner could obtain the relevant rights according to the arrangement they made. The company argued that each combination could be viable depending on the parties' capabilities and interests. It also wanted the network framework to recognize existing authorizations and avoid encumbering permissions already obtained. These requests were consistent with a system capable of serving multiple partners. They also left responsibility to be defined through both permissions and contracts. Flexibility did not mean that no one needed to hold the rights. It meant Starlink opposed a rule deciding in advance which party had to hold each one. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for...
For direct-to-device use of mobile spectrum, Starlink supported working with one or several service providers whose holdings together covered the country. It opposed requiring a single partner to hold the same channel across all twenty-two licensed service areas. The response also opposed regulating charges exchanged between a network entity and its service partners. It wanted the parties to negotiate prices and conditions. That proposal connected the company's technical flexibility to commercial flexibility. A network could be integrated with different providers and different spectrum arrangements without a prescribed wholesale price. Whether the regulator should accept that degree of freedom remained an open question within the process, especially where a partner depended on a network it did not control. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for...
Starlink supported deducting charges paid by a service provider to the network entity from the former's applicable gross revenue. It said the purpose was to avoid charging the same revenue twice. For financial conditions and spectrum-payment terms, it wanted treatment analogous to service-authorized entities. This position was distinct from its opposition to regulating the commercial price between partners. The company could seek freedom to negotiate that price while also seeking a specified treatment of the payment in government charges. The response therefore addressed two different layers: what one business could charge another, and what amount the government should use when calculating the businesses' regulatory obligations. The relationship between those layers would affect the economics of network sharing. trai.gov.in, Subject: Starlink India Responses to TRAI Consultation Paper on "Framework for...