VNOAI Proposes DoT Intervention on LSA-Based Wireline VNO Routing and SDCA Numbering Challenges

• Dependency on parent NSOs: VNOs rely on their parent NSOs for numbering resources, interconnection and appropriate routing facilities.

A separate physical softswitch in each SDCA is not inherently necessary with modern IP technology. However, without suitable interconnection and routing arrangements, the cost of additional distributed infrastructure could make LSA-wide Wireline Access VNO operations commercially unviable.

2. VNOAI’s Proposed Solution: Centralised LSA-Level Call Routing

VNOAI proposes that DoT facilitate an appropriate technical framework enabling Wireline Access VNOs to serve subscribers across their authorised LSA using a centralised IP-based softswitch or SIP platform.

Under this arrangement, parent NSOs would provide suitable IP-based routing gateways and interconnection facilities for delivering calls to VNO customers across multiple SDCAs.

The proposed solution would:

1. Enable centralised management of wireline calls across an LSA.
2. Reduce unnecessary duplication of network infrastructure.
3. Allow efficient management of SIP/PRI, DID and enterprise voice services.
4. Improve utilisation of existing parent NSO infrastructure.
5. Reduce operating costs and improve commercial viability.
6. Encourage competition and wider availability of wireline services.

The framework would continue to preserve applicable numbering, subscriber identification, emergency calling, lawful interception and network security requirements.

3. Role of Fixed-line Location Routing Number (FLRN)

TRAI, in its recommendations dated 6 February 2025 on Revision of the National Numbering Plan, proposed significant reforms to India’s fixed-line numbering architecture.

These include migration towards an LSA-based 10-digit closed numbering scheme and the subsequent introduction of a Fixed-line Location Routing Number (FLRN) framework.

FLRN is intended to provide a network-level mechanism for identifying the appropriate destination network or routing location independently of the traditional geographic interpretation of the subscriber’s telephone number.

VNOAI believes that an FLRN-based or equivalent routing framework could provide an effective long-term solution for enabling centralised wireline routing across an LSA.

The Association proposes that DoT examine appropriate VNO-specific arrangements, including routing identifiers or number-mapping facilities managed through parent NSOs.

TRAI’s FLRN proposal remains a recommended reform; its implementation and detailed applicability to VNOs require further decisions and instructions from the concerned authorities.

4. Interim Arrangements to Support Wireline VNOs

Considering that implementation of a revised National Numbering Plan may require substantial coordination between telecom operators, VNOAI proposes an interim solution.

Under the proposed arrangement:

• Existing SDCA-based numbering resources may continue to be used in accordance with prevailing rules.
• Parent NSOs may provide centralised LSA-level SIP/IP routing gateways to authorised Wireline Access VNOs.
• Calls associated with existing SDCA number ranges may be routed to centralised VNO platforms through appropriate number-mapping and signalling arrangements.
• Separate physical switching infrastructure in every SDCA should not be imposed where technically unnecessary.
• Parent NSOs should provide the necessary routing and interconnection facilities on fair, reasonable and non-discriminatory terms.

Such an arrangement could help VNOs commence or expand their services under the new authorisation framework without waiting for nationwide FLRN implementation.

5. Proposed Representation by VNOAI to DoT

VNOAI proposes to submit a detailed technical and regulatory representation to the Secretary (Telecommunications), DoT, and Member (Technology), Digital Communications Commission, with copies to Member (Finance), the concerned DDGs handling Access Services and Numbering Resources, and other relevant authorities.

The proposed representation will seek:

• Early clarification permitting centralised LSA-wide call-control infrastructure for Wireline Access VNOs.
• Expedited consideration and implementation of TRAI’s recommendations on LSA-based fixed-line numbering.
• Development of an FLRN or equivalent routing mechanism suited to the VNO operating model.
• Appropriate LSA-level IP interconnection and routing arrangements through parent NSOs.
• Protection against disproportionate infrastructure, transmission and interconnection costs.
• A standardised and non-discriminatory NSO–VNO technical framework.
• Consultation with VNOAI and industry stakeholders before finalising the technical implementation arrangements.

VNOAI also proposes that DoT consider constituting a technical working group involving DoT, TRAI, TEC, NSOs and VNO representatives to examine the practical implementation of these measures.

6. Why This Reform Is Important for India’s Telecom Sector

The introduction of LSA-based Wireline Access VNO Authorisations is an important step towards expanding opportunities for smaller telecom service providers.

However, the benefits of the new regime can be realised only if its implementation is supported by modern numbering, routing and interconnection arrangements.

VNOs should be able to utilise the existing infrastructure of parent NSOs efficiently rather than being required to duplicate network facilities across numerous SDCAs.

An appropriate LSA-wide routing framework would help:

• Promote greater competition in wireline telecommunications.
• Encourage small and medium telecom operators to expand services.
• Reduce unnecessary infrastructure expenditure.
• Improve the availability of enterprise communication services.
• Support telecom connectivity in underserved regions.
• Advance the objectives of the Telecommunications Act, 2023 and India’s digital connectivity initiatives.

7. VNOAI Invites Industry Feedback

VNOAI invites its members, especially existing Category-B VNO licensees and providers of SIP/PRI, DID, fixed-line and enterprise voice services, to share their experiences and suggestions regarding:

• SDCA-wise numbering and routing difficulties.
• Technical restrictions encountered with parent NSOs.
• Additional infrastructure or interconnection expenditure.
• Feasibility of centralised LSA-wide routing.
• Practical implementation of FLRN or equivalent solutions.

These inputs will assist the Association in finalising its collective industry representation to DoT.

Conclusion

LSA-based Wireline Access VNO Authorisations require an equally modern LSA-wide numbering and routing framework.

VNOAI believes that centralised IP-based routing, supported by appropriate parent NSO interconnection facilities and eventual implementation of an FLRN-based architecture, can significantly reduce infrastructure costs and improve the commercial sustainability of Wireline Access VNO services.

The Association will continue to engage with DoT, TRAI and other concerned stakeholders to promote a technically efficient, financially viable and competitive VNO ecosystem in India.

📄 Download Official VNOAI Circular (PDF)