Airtel has told the Telecom Regulatory Authority of India (TRAI) that network slicing should not be treated as ordinary technology-neutral quality-of-service (QoS) differentiation, arguing that it is a distinct 5G capability. The position comes in its September 15 counter-comments to TRAI’s consultation on amendments to its 2024 QoS regulations. The submission responds to a stakeholder position that QoS differentiation should be permitted across 4G, 5G and future technologies.
Reliance Jio and GSMA had separately argued for greater flexibility around network slicing, including for enterprise and application-specific services in their comments. Airtel’s response instead seeks a regulatory distinction between ordinary QoS differentiation and 5G slicing, while its September 2 comments oppose TRAI’s proposed 21-day advance notice for creating new slices.
1. Network slicing is distinct from differentiated QoS
In its counter-comments, Airtel argues that technology neutrality cannot mean treating technically different network capabilities as interchangeable. “Network slicing is not merely a commercial label for differentiated speeds, tariff tiers or priority treatment,” the company said. It described slicing as “a specific 5G architectural capability involving the creation and management of logical network instances over shared infrastructure with defined service, resource and performance characteristics.”
The submission distinguishes slicing from bearer-level prioritisation, APN policies, traffic management and tariff-linked differentiation, which can operate across 4G, 5G and future technologies. These mechanisms, it said, “do not, by themselves, create a network slice.” Treating them as equivalent could create “regulatory ambiguity, consumer confusion and avoidable compliance uncertainty”.
The distinction is also relevant to how differentiated services are treated under consumer protection and non-discrimination rules. The submission says ordinary differentiated QoS should continue to be governed by “tariff transparency, consumer protection and non-discrimination safeguards”, while network slicing should be addressed separately when an operator actually creates and manages a 5G slice.
2. 4G priority services should not be treated as 5G slicing
In its counter-comments, the company also draws on TRAI’s earlier treatment of differentiated services on 4G. It says some Indian telecom providers offered priority treatment and faster speeds on 4G in 2019 and 2020, with those offerings subsequently attracting TRAI scrutiny over transparency, non-discrimination and their impact on other users.
“Network slicing is purely a feature of 5G technology and not 4G,” the submission said. It therefore argues that differentiated treatment on 4G cannot be characterised as network slicing.
The submission also points to TRAI’s April 2022 recommendations on spectrum identified for IMT/5G, which recognised network slicing within the 5G private-network and enterprise-service framework and recommended specific licensing provisions for such uses.
It consequently asks TRAI to maintain a “clear and enforceable distinction”: general QoS parameters can remain technology-neutral, but network-slicing obligations should apply only where a genuine 5G slice exists. Treating both as a single category, it said, could impose slicing obligations on conventional 4G QoS mechanisms while reducing genuine 5G slicing to “ordinary priority handling”.
3. 21-day advance notice would undermine network slicing
In its September 2 comments, Airtel opposed TRAI’s proposal requiring operators planning a new 5G network slice to provide details of proposed and existing slices 21 days in advance, including information demonstrating sufficient capacity.
The company said the requirement should be “dropped in its entirety”, arguing that network slicing is intended to provide “agility, flexibility and rapid deployment of differentiated network capabilities for specific requirements”.
The comments point to possible enterprise deployments, industrial applications, major events, emergency-response requirements and specialised services. A mandatory 21-day notification period, it said, could prevent operators from responding to such requirements promptly and turn an internal network decision into “a regulatory approval-like process”.
The comments also describe network slicing as a “nascent and rapidly evolving technology” and argue that regulation should accommodate developing use cases rather than establish a rigid ex-ante process. The company therefore asks TRAI not to introduce any requirement that operates as an ex-ante approval mechanism for creating a new slice.
4. Focus on consumer impact rather than how a slice is configured
Airtel’s comments propose that TRAI address the potential impact of slicing through existing customer-facing QoS requirements rather than regulating the creation of individual slices.
The submission says the concern is whether slicing could affect subscribers using the non-sliced portion of a network.
However, “this concern is already capable of being addressed through the existing network availability, throughput/speed and other applicable QoS benchmarks”. If a slice causes material degradation, the company argues, that impact should appear in customer-facing parameters.
It therefore proposes that any information TRAI considers necessary be collected after deployment, preferably quarterly. Such reporting could cover the number of slices, their broad use case, high-level parameters and confirmation that applicable QoS requirements were maintained.
5. Airtel points to the US and UK for regulatory cover
The company also leaned on comparative regulatory practice to argue against an ex-ante approval process. Airtel says TRAI has “not indicated any international precedent for the proposed framework” and that it is unaware of any jurisdiction imposing a mandatory prior-notification requirement before a slice can be created.
It cites the US Federal Communications Commission as having taken a monitoring rather than restricting approach, allowing slicing to keep developing while watching for effects on broadband performance rather than imposing a blanket ex-ante restriction. It draws a similar comparison with UK regulator Ofcom’s work on 5G slicing, which the submission says recognises the technology’s potential for demanding use cases such as emergency communications, advanced manufacturing and energy distribution, while highlighting the flexibility and agility slicing can provide.
On that basis, Airtel argues the Indian proposal would be more restrictive than anything currently in force in either the US or the UK, and asks TRAI to favour post-facto monitoring over prior clearance accordingly.
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