On June 6, 2025, the Internet Society (ISOC) held Peering RoadShow — India Edition, organised by MediaNama. Important in this context are the recommendations of the Telecom Regulatory Authority of India (TRAI), that Internet Exchange Points (IXPs) in the country need to be authorised to function, apart from the imposition of other regulatory obligations, such as providing for monitoring of intrusions, attacks and frauds in technical facilities, blocking of websites and subscribers, as well as restrictions from operating in specific areas in India. The ongoing discourse has highlighted issues between telecom operators and other players concerning issues like licensing, quality-of-service compliance, and peering arrangements. 

The objectives of the peering roadshow were to:

  • Strengthen Local Peering Ecosystems: By supporting collaboration among Internet Service Providers (ISPs), IXPs, Content Delivery Networks (CDNs), data centre operators, and other infrastructure actors.
  • Advance Best Practices: Through practical sessions and discussions focused on routing, traffic engineering, interconnection architecture, and network operations.
  • Address Regulatory and Policy Implications: Understand the implications of the recent authorisation requirements for IXPs and their operating constraints.
  • Facilitate Neutral, Cross-Sector Dialogue: Between telecom operators, cloud providers, content networks, and civil society, and identify solutions.
  • Promote Security and Resilience: Discuss operational preparedness for network attacks, monitoring obligations, and the role of IXPs in ensuring digital sovereignty.

The Peering RoadShow included a workshop on the current state of interconnection in India, peering best practices, and how the Middle East and North Africa (MENA) look at interconnection regulation. The event also featured a roundtable, which covered the state of peering and its regulation in India and in other parts of the world. 

Download a copy of the event report here

Executive summary

In February this year, TRAI recommended that the Government should bring IXPs under an authorisation regime. As per the framework TRAI has suggested for this regime, IXPs will have to block content and subscribers in the interest of national security, will have to create facilities for monitoring intrusions, attacks, or faults, and provide reports on the same to the Central Government. Meanwhile, CDNs are outside the scope of authorisation, with the only requirement that the players have to go through being that the agreements they have with other entities are fair, non-discriminatory, and compliant with net neutrality objectives. 

During ISOC’s Peering RoadShow– India Edition, which delved into the TRAI recommendations and the current state of interconnection in India, stakeholders pointed out that in the past decade, private Internet Exchanges (IXs) have entered the Indian market. Further, more content providers also cache their content in India now. However, telecom companies continue to not peer much at IXPs. This is because of two key reasons: there is an absence of ISP-to-ISP peering in Indian IXs, and Indian telcos believe that they can ensure better service quality if they host cache servers within their own networks. Stakeholders argued that of the 80-90 terabytes of data currently moving through India, IXPs handle only 7-8 terabytes which implies market failure for the IXP ecosystem. Others added that this market failure has less to do with IXP operations and more to do with circuit availability and the scope for content players and ISPs to reach an IX. 

One of the key points that stakeholders debated was whether IXPs and CDNs even fall within the scope of the Telecommunication Act and, hence, whether they even fall within the scope of services that the Government can mandate a license for. While some argued that, given the broad definition of the telecommunication services under the Act, one could interpret that IXPs provide ‘transmission’ services which fall within the scope of the Act. The others disagreed, instead elaborating on the reasons why IXPs do not require a license by looking at a 2013 Delhi High Court (HC) judgment which stated that licensees under the TRAI Act (which is the only Act that defines a licensee) is anyone who provides services to the end customer. Since IXPs don’t do that, they remain outside the scope of licensing. 

Another point that was brought up was the rationale behind why telecom companies in India have pushed for the inclusion of IXPs within the licensing regime. Some stakeholders pointed out that telecom companies are seeking regulatory parity given the onerous requirements of their own license. They argued that the Government should give a common guideline for all players in the ecosystem to uphold a certain standard of security, service quality, and latency. Others pointed out that the security requirements for telcos and IXPs cannot be similar because the former can directly identify customers and customer activity, while the latter cannot. On the quality of service front, some stakeholders pointed out that market forces can ensure that IXPs maintain a high quality of service, because if they don’t, content providers and telcos can simply shift to other IXPs or even peer amongst themselves.

A key point of discussion was whether IXPs can even fulfil the requirements that the authorisation regime sets out, especially content blocking and surveillance. Discussing these requirements, stakeholders pointed out that IXPs cannot see into data packets, given that almost everything on the internet is encrypted today. They also mentioned that asking IXPs to do so would be the equivalent of asking fibre conduits to surveil data. 

With regards to blocking requirements, speakers at the discussion argued that at most, IXPs can block the ports of a specific content provider. However, by doing so, they not only block a specific URL but also a complete website/service provider. They mentioned that even telecom companies today cannot effectively block specific pieces of content because of the HTTPS protocol. As a result of this, some suggested that to block specific content, the Government should directly contact CDNs. Others argued that certain niche websites are located outside of India and do not have any presence in Indian CDNs; to block these sites, the Government can contact telcos. 

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Discussing the impact of licensing requirements, stakeholders with licenses suggested that not much would change for them, whereas others argued that it would be a major setback to community IXs, which may shut down in the face of onerous authorisation requirements. These IXs help spread broadband connectivity to areas where private IXs do not see commercial viability. 

When asked whether mandatory peering could be a method to ensure greater connectivity, stakeholders unanimously disagreed with the idea. They believe that forced peering is only necessary in regions where a specific telco has a termination monopoly, which is not the case in India. They mentioned that certain Government tenders currently mandate that telcos must peer at the National Internet Exchange of India (NIXI). However, this mandatory peering requirement has proven to be ineffective, with telcos who peer as a result of such tenders not announcing their routes or providing enough capacity. 

Finally, speakers emphasised the importance of customised regulatory approaches for IXs, which should be based on factors like market maturity, size, competitiveness, and local business culture. A one-size-fits-all solution is not effective across different countries and markets.

Video and Coverage:

MediaNama’s coverage of the discussion can be found here.

The community partners for this event are the Internet Society, Delhi Chapter, and Broadband India Forum (BIF).

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