TELECOM ACT 2023 MIGRATION
“FROM LEGACY LICENCE TO THE NEW TELECOMMUNICATIONS AUTHORISATION FRAMEWORK.”
The Telecommunications Act, 2023 introduces a new authorisation framework for telecom services and networks. Existing licences and permissions may have a migration pathway under the applicable 2026 rules. TeleTax Solutions helps operators assess their existing position, prepare required documentation, and manage the migration process.
*Migration applicability depends on the existing licence, registration, permission, service, service area, and applicable Telecommunications Act, 2023 migration framework.
Legacy licences with definite validity may continue for their duration, or voluntarily migrate to the 2026 Authorisation terms.
LEGACY NEW-APPLICATION ROUTE HAS CHANGED & CONTINUATION RIGHTS APPLY
The official Department of Telecommunications (DoT) framework establishes two core statutory principles:
1. Fresh Telegraph Act Intake Stopped: DoT has stopped accepting new applications under the Indian Telegraph Act, 1885 for Unified Licences, UL-VNO, standalone licences, and registrations on Saral Sanchar / NSWS. Fresh entrants must apply for Authorisations on the new Authorisation Portal.
2. Existing Definite-Validity Licences May Continue: A licence, registration, or permission granted with a definite validity period under the Indian Telegraph Act, 1885 or Wireless Telegraphy Act, 1933 is entitled to continue under its specified terms and conditions for its remaining duration, OR may opt to migrate to the relevant authorisation under the 2026 Rules.
Therefore, migration is not automatically mandatory for every telecom operator immediately. The applicability and route must be mapped against your specific licence tenure, service area, and business roadmap.
WHAT IS TELECOM ACT 2023 MIGRATION?
Migration is the legal transition process under Section 3(6) of the Telecommunications Act, 2023, allowing eligible holders of legacy licences, registrations, or permissions to adopt the terms and conditions of corresponding authorisations. It does not mean applying as a greenfield entity; rather, it transitions active operating standing into the modernized statutory framework.
Indian Telegraph Act, 1885
Characterized by individualized contract agreements, multi-tier bank guarantees, rigid service demarcations, and legacy portal workflows.
- Unified Licence (UL) & UL-VNO multi-schedule agreements
- Complex Performance & Financial Bank Guarantee covenants
- Governed through legacy Saral Sanchar interfaces
Telecommunications Act, 2023
Characterized by standardized rule-based authorisations, streamlined fee structures, digital governance, and structured civil adjudication.
- Authorisation Certificates governed by codified 2026 Rules
- Integrated digital management via the DoT Authorisation Portal
- Standardized categories for Networks, Services & Captive links
YOUR TELECOM TRANSITION DECISION TREE
Select your current operating status to examine the statutory route prescribed under the 2026 framework:
Option to Continue Under Existing Terms OR Migrate to Authorisation
Under Section 3(6) of the Act and DoT migration guidelines, your business is legally permitted to continue operations under the terms, conditions, and validity period specified in your existing grant. Alternatively, you may choose to migrate to the corresponding Authorisation on the DoT Authorisation Portal to align with unified compliance and fee rules.
MIGRATION VS NEW AUTHORISATION VS RENEWAL
Distinct regulatory concepts that should not be confused:
Telecom Act Migration
For Existing Active Licence Holders
- Converts existing Telegraph Act licence into Authorisation
- Preserves current operating standing & service area
- Processed via DoT Authorisation Portal migration desk
New Authorisation
For New Telecommunication Businesses
- Fresh application under 2026 Authorisation Rules
- Full verification of corporate net worth & capital
- Does not rely on any historical operating instrument
Licence Renewal
Old Framework Extension
- Continuation under old Telegraph Act 1885 terms
- Discontinued for fresh grants; superseded by Migration
- Expiring licences must migrate to secure future validity
DO NOT MIGRATE WITH UNRESOLVED COMPLIANCE GAPS
Migration does not erase an operator's compliance history. Past statutory liabilities, Adjusted Gross Revenue dues on SARAS, TRAI filing records, and security undertakings carry over. A clean baseline is critical:
Ensure past quarterly revenue statements and Licence Fee payments match audited books without unverified deduction claims.
View AGR Filing Details →Verify that Performance Monitoring Reports (PMR), tariff filings, and consumer grievance matrices are up to date.
View TRAI Filing Services →Ensure Chief Telecommunication Security Officer board appointment is documented and ICDR portal enrollment is active.
View Security Compliance →Verify active routers and switches against Trusted Telecom Portal product approvals and TEC MTCTE testing certificates.
View TTP Compliance Details →TELECOM ACT 2023 TRANSITION TIMELINE
Key gazette notifications and official DoT implementation dates:
Migration Rules Notified
DoT gazettes the Terms and Conditions for Migration Rules, 2026, establishing the legal parameters for legacy licence conversion.
Authorisation Portal Migration Live
Official DoT Authorisation Portal activates the dedicated migration gateway for existing licensees.
Telecommunication Network Rules
Notifies standardized conditions for Network Service Operators and transmission infrastructure.
Network Rules Live on Portal
Network service authorisations become fully operational for digital intake across DoT eServices modules.
YOUR DEDICATED TELECOM MIGRATION TEAM
Telecom Act 2023 migration is not just a portal submission. The existing licence, authorized service, service area, regulatory history, and corresponding authorisation must be mapped before the migration route is pursued.
Our dedicated expert team helps review the legacy licence, identify the applicable migration pathway, organize documentation, prepare the application, coordinate responses, and establish the post-migration compliance roadmap.
Licence covenants & service area.
Reconcile AGR, TRAI & security.
Authorisation Portal filing.
Post-migration 2026 calendar.
TeleTax Migration Advisory Scope
- Legacy Licence Scope & Schedule Review
- Corresponding 2026 Authorisation Category Mapping
- Pre-Migration AGR & Statutory Dues Reconciliation
- DoT Authorisation Portal Application Filing
- Scrutiny Query & Deficiency Management
- Bank Guarantee Adjustment Coordination
- Post-Migration Statutory Compliance Onboarding
TELECOM ACT 2023 MIGRATION SUPPORT ACROSS INDIA
Assisting Unified Licence holders, ISPs, and Virtual Network Operators across major telecom circles:
FREQUENTLY ASKED QUESTIONS
Answers covering Section 3(6) of the Act, 2026 Migration Rules, the Authorisation Portal, and licence continuation rights.
IS YOUR LEGACY TELECOM LICENCE READY FOR THE NEW FRAMEWORK?
Understand your existing licence position, migration applicability, documentation, regulatory gaps, and post-migration compliance requirements before proceeding.