When a fishing vessel off the Andaman Islands transmits its position through a satellite network to an overseas destination, or when an individual in a border district sends an encrypted message through a foreign satellite system that bypasses every terrestrial telecommunications tower in India, an important question arises. Who has visibility over the communication pathways? Who verifies identity, authentication, and regulatory compliance across such transmissions?
Under India's present regulatory architecture, the answer may not always be straightforward. That is a challenge with implications extending beyond telecommunications administration into the realm of sovereignty itself.
A new generation of satellite technology, Low Earth Orbit Direct-to-Device communications, or LEO D2D, is poised to make such scenarios increasingly routine rather than an exception. India may soon need to determine whether it governs this emerging communications ecosystem on its own terms, or adapts to frameworks shaped elsewhere.
The network is global, but the jurisdiction is national. This asymmetry lies at the heart of the challenge that satellite direct communications create. Addressing it will require more than incremental regulatory adjustment; it may, in fact, demand a new governance approach.
What LEO D2D actually means
Traditional satellite communications depended upon expensive, specialised terminals and dedicated handsets. The next generation is fundamentally different. Emerging systems, such as SpaceX Starlink Direct to Cell, AST SpaceMobile, and Lynk Global, are designed to enable ordinary smartphones—the same devices already carried by billions of users like you and me—to communicate directly with satellites in Low Earth Orbit. The smartphone communicates directly with a satellite that effectively functions as an orbiting radio access node or a cell tower in space. To the user, the connection can appear seamless, global, and largely independent of conventional terrestrial telecommunications infrastructure.
Global deployment momentum of such systems is accelerating, with services already available in several nations. International operators are increasingly engaging with the Indian market and the regulatory ecosystem. Yet, whilst technology deployment is advancing rapidly, governance frameworks for direct satellite connectivity are still evolving.
This matters because the technology promises major societal benefits. Satellite D2D could transform communications access in remote regions, support maritime safety, strengthen disaster response, and expand digital inclusion across underserved areas. Yet, like every communication revolution, it also raises important questions regarding oversight, resilience, sovereign control, and enforcement.
Three emerging vulnerabilities
The implications of unregulated or inadequately governed D2D connectivity over Indian territory can be grouped into three broad areas.
1. Identity
India has built a robust subscriber identification architecture for terrestrial communications through SIM registration systems, device identification processes, and lawful intercept mechanisms.
Satellite D2D systems introduce new complexity. Subscriber identity information may reside in databases maintained by operators located in other jurisdictions. Access to such information during time-sensitive investigations could potentially depend upon international legal processes that are often slower than operational needs.
This does not imply anonymity, but it can create visibility and responsiveness gaps that traditional domestic systems were designed to avoid.
2. Gateway Location
Lawful access and regulatory oversight of communications are often most effective where network traffic is routed through terrestrial gateways. These are part of the licensing conditions for telecom operators.
At present, India possesses localisation provisions within its telecommunications licensing framework. However, the emergence of direct-to-device satellite systems would create new regulatory challenges that may not fit neatly within terrestrial assumptions. Because large satellite footprints can span across border regions and maritime areas, communications involving users in India could potentially traverse infrastructure outside Indian territory unless explicit D2D-specific requirements are established. Questions therefore emerge regarding jurisdiction, legal oversight, and operational responsiveness.
3. Signal Control
Modern LEO systems increasingly employ software-defined architectures capable of dynamically controlling service coverage across geographic regions.
Coverage management decisions may ultimately rest with private operators headquartered outside India and operating under their own legal and regulatory environments. The entire management of services, including network management and security operations, could, in many deployment models, be handled overseas.
Public reporting during recent international conflicts demonstrated that commercial satellite services can become deeply intertwined with geopolitics. The broader lesson, therefore, is not about any single company or conflict; it is simply that strategic communication infrastructure may increasingly shape national security outcomes.
Can sovereign communications resilience rely exclusively upon external commercial ecosystems?
The maritime dimension
India's maritime domain presents perhaps the most complex challenge.
With a coastline of approximately 7,500 kilometres and an Exclusive Economic Zone (EEZ) spanning over 2 million square kilometres, large areas of India's maritime space remain beyond terrestrial telecommunications coverage. Satellite communications naturally become the primary medium for fishing communities, commercial shipping, disaster response, and maritime operations.
This creates opportunities but also raises regulatory and enforcement questions. Communications occurring through overseas satellite systems across vast maritime spaces may present reduced visibility and limited capability to ensure situational awareness, as compared with conventional terrestrial systems.
The challenge becomes particularly important in the case of the Andaman and Nicobar Islands. Positioned close to one of the world's most important maritime chokepoints and hosting strategically significant military infrastructure, the islands occupy a unique place in India's security architecture. However, the region continues to depend a great deal on satellite-enabled connectivity, despite the Chennai–Andaman Island (CANI) submarine cable system. As India simultaneously pursues greater economic and infrastructure ambitions in the region, communication resilience assumes increased strategic significance.
India has capabilities, but capability alone is not governance
India today begins from a position of considerable strength in the space sector. The country possesses independent launch capability, a mature space programme, an increasingly vibrant private sector ecosystem, and one of the world's largest smartphone user bases.
The issue is, therefore, not a technological challenge. Rather, it is the absence of a comprehensive governance architecture capable of translating national capability into sovereign control.
Unlike conventional satellite services, D2D systems increasingly share spectrum environments closely aligned with terrestrial mobile services. Coordinating spectrum use, avoiding harmful interference, and defining operational precedence during emergencies may therefore become critical governance challenges.
India Has |
India Still Needs |
Independent launch capability |
Gateway localization framework for D2D operators |
Operational NavIC capability |
Non Terrestrial Network (NTN) compatible registration framework |
Mature lawful intercept systems |
Extension of legal frameworks to D2D services |
Large digital ecosystem |
Integrated governance mechanism |
Expanding private space ecosystem |
National NTN monitoring capability |
Telecom Act 2023 foundation |
Specific D2D service rules |
A five-point framework for action
The objective should not be to deny or restrict satellite communications. Their developmental and strategic benefits are substantial. The challenge is to shape their adoption on terms aligned with India's sovereign interests.
1. Introduce Gateway Localisation Requirements Operators serving users within India should progressively establish gateway infrastructure within Indian territory. This can significantly improve regulatory visibility and responsiveness whilst maintaining operational flexibility. Sensitive maritime and border regions may require enhanced monitoring protocols.
2. Extend Registration Frameworks to Non-Terrestrial Networks India's existing subscriber identity systems represent a significant institutional advantage. These frameworks should evolve to accommodate satellite D2D environments whilst accounting for practical considerations such as international roaming, maritime users, and emergency situations.
3. Create an Integrated Governance Structure Responsibility for the regulation of space-based communication systems currently spans multiple institutions, including telecommunications, space, security, defence, maritime, and digital ministries. An immediate inter-ministerial task force could serve as an initial mechanism, which can evolve into a dedicated authority as the ecosystem matures.
4. Issue Non-Terrestrial Service Rules Under the Telecom Act 2023 India already possesses legislative foundations through the Telecom Act. Specific service authorisations, technical standards, lawful access provisions, and operational requirements for satellite D2D should ideally precede large-scale deployment. Early clarity on such issues strengthens India's long-term negotiating position. Spectrum coexistence and coordination between terrestrial and non-terrestrial systems will also require careful regulatory planning.
5. Explore NavIC Direct Messaging Capability China's BeiDou system has demonstrated how sovereign navigation systems can incorporate messaging functions alongside positioning services. India could examine similar pathways for NavIC, particularly for maritime communication, disaster response, remote connectivity, and strategic applications. Such capabilities could create an important sovereign complement to commercial satellite ecosystems.
An economic opportunity, not merely a security question
The debate surrounding D2D connectivity should not be framed solely through a security lens. A sovereign architecture for satellite communications could stimulate domestic innovation in gateway infrastructure, NTN (non-terrestrial network) software ecosystems, secure communication platforms, device manufacturing, and space-sector entrepreneurship. India's expanding private space ecosystem, in fact, provides an opportunity not merely to regulate technology adoption, but to shape and participate in emerging global markets.
Regulatory clarity can therefore become an enabler of growth rather than a barrier to it.
The geopolitical stakes
Only a small number of countries currently possess end-to-end sovereign capability across launch systems, satellite architecture, and strategic communications ecosystems. Many nations continue to depend upon external commercial platforms or are building transitional arrangements. India now stands at an important decision point.
The larger lesson from current global developments is that communication infrastructure increasingly occupies a strategic space between commerce, technology, and national security. Dependencies formed today may shape strategic flexibility tomorrow.
This is not an argument against international partnerships or foreign investment; India will continue to benefit from both. Rather, it is an argument that the terms of engagement should preserve sovereign authority over communications occurring within Indian territory and maritime spaces. These objectives are not contradictory, but they are easier to establish before large-scale dependence emerges.
Making the iInvisible border visible
India is today a major space power and one of the world's largest digital societies, with demonstrated technological capability. It possesses many of the ingredients necessary to shape the future of satellite direct communications.
What remains is urgency.
Satellite systems are expanding and market actors are arriving. Policy windows tend to narrow once technological ecosystems become entrenched. India's invisible border in space may therefore need to become visible, enforceable, and sovereign. The architecture to achieve this already exists in fragments. The challenge now is bringing those fragments together before strategic realities make the choices significantly harder.
History often shows that infrastructure dependencies become visible only after crises emerge. India still has a rare advantage: the opportunity to shape the rules before dependence hardens into reality. Invisible borders in space are still borders. The question is whether India chooses to define them before others do.
(Lt Gen M U Nair (retired) is the former National Cyber Security Coordinator, Government of India, and a former Signal Officer in Chief, Indian Army.)
(The opinions expressed in this article are those of the author and do not purport to reflect the opinions or views of THE WEEK.)