On an Indian mobile connection, international roaming is supposed to sit switched off until you personally ask for it. That one line of regulation is the line almost nobody has read, and it is the line that decides a disputed bill.
| What most people assume | What the regulation actually says |
|---|---|
| Roaming is always on, that is just how a phone works | International mobile roaming “is inactive by default for all consumers” |
| The operator can switch it on for me as a convenience | It shall be “activated only on the request of a consumer” |
| Nobody has to warn me before charges start | Land abroad with no roaming pack and the operator must SMS you about the possibility of incurring significantly high charges at standard rates |
| I will get an alert as my bill climbs | The percentage alerts are tied to your pack data entitlement, not to any rupee amount |
| Once it is on I am stuck for the whole trip | It “may be deactivated at any time on the request of the consumer” |
| The regulator will refund me if I complain | TRAI states that the TRAI Act, 1997 does not envisage handling of individual consumer complaints by TRAI |
Regulation 17, Telecom Consumers Protection Regulations, 2012. “Every service provider shall ensure that the international mobile roaming service is inactive by default for all consumers and shall be activated only on the request of a consumer and once activated, it may be deactivated at any time on the request of the consumer.”
That text was not in the 2012 regulations as first written. It arrived as a whole new Chapter VI, headed “Measures to protect consumers from bill shocks while using international mobile roaming service”, inserted by the Telecom Consumers Protection (Eleventh Amendment) Regulations, 2020, notified on 30 September 2020 and in force from 30 October 2020. TRAI republished the consolidated Telecom Consumers Protection Regulations on 28 March 2025, updated to the twelfth amendment, and regulations 17 to 23 appear there word for word. That March 2025 consolidation is the current published version on the TRAI site.
One proviso decides a lot of arguments. For people who already held the connection when the amendment was published, the operator was permitted to take their specific choice, to continue or to discontinue an already active roaming, through SMS, email or mobile application within thirty days of publication. So an old number can carry lawfully active roaming. What regulation 17 hands you is a consent argument, not an automatic refund.
| When | What must reach you | Regulation |
|---|---|---|
| Immediately on activation | The fact of activation, and the applicable tariff, one time charges as well as recurring | 18 |
| Immediately on selecting a tariff | Voice, SMS and data rates abroad, which visiting carriers to select, a list of actions to avoid bill shocks, the consumer protection policies in place, or a URL to all of it | 19 |
| The moment you switch the handset on abroad | Everything in regulation 19, plus an SMS warning if you have not subscribed to any roaming tariff pack, about significantly high charges at standard rates | 20 |
| As your pack data burns down | An alert at fifty per cent, eighty per cent, ninety per cent and one hundred per cent of the data entitlement | 21 |
| If you drift into a country or zone your pack does not cover | Notice that you have moved outside the opted tariff, a warning about standard rates, and the tariff for that zone | 22 |
| On demand while abroad | A toll free short code that returns your applicable roaming tariff and the amount billed or charged to your account | 23 |
Regulations 18, 19, 21 and 22 are all delivered “through SMS, email and mobile application, if available”. The regulation 20 warning is specifically by SMS. The short code under regulation 23 is allotted by each operator, so ask yours for the number before you fly.
Read regulation 21 slowly. The alerts fire “when the data usage exceeds fifty per cent, eighty per cent, ninety per cent and one hundred per cent of the data entitlement”. Three limits are baked into that sentence.
That is why the percentage ladder is the wrong argument for most shock bills. If you travelled without a pack, your rules are regulation 20 and regulation 22: the switch on warning and the wrong zone warning. Ask for proof that both were sent, to the number and the email on record, with timestamps.
Illustrative only. Figures show the shape of a dispute, not any operator tariff.
Nikhil Barve of Pune flew to Singapore for six days, then took a two day side trip to Malaysia. He bought a roaming pack for the Singapore leg. His next postpaid bill came to ₹61,400.
He paid the ₹8,199 he did not dispute, and raised a written billing complaint over the ₹53,201. His case was not that the tariff was wrong. It was that he received nothing on entering the uncovered zone, no notice that he had moved outside the opted tariff, no warning about standard rates and no tariff for that zone, which is exactly the trio regulation 22 requires.
For the document by document walkthrough of that dispute, including how to demand usage logs and the activation record, use Postpaid bill inflated by roaming data charges. If you are still planning the trip, the activation side is covered in How to activate international mobile roaming.
You cannot file an RTI application against your mobile operator. You can file one against the regulator. Under the 2012 complaint redressal regulations every service provider must submit quarterly reports on appeals to TRAI and publish them, and the March 2026 direction required a compliance report with URLs and screenshots within fifteen days. Those filings sit with a public authority, so an RTI application to TRAI or to the Department of Telecommunications can ask what was reported and what action followed. Draft it with the AI RTI Drafter, track the thirty day clock on the Timeline Tracker, and if the reply is evasive, run it through the PIO Reply Checker before you build a first appeal on the First Appeal Builder. The long form method is in The RTI Playbook.
Regulation 17 requires every service provider to ensure the service is inactive by default for all consumers and to activate it only on the request of a consumer. The one carve out is the proviso for people who already held the connection when the amendment was published in 2020, whose choice to keep or drop an already active roaming could be taken by SMS, email or app within thirty days.
Under regulation 21 the operator must alert you when data usage exceeds fifty per cent, eighty per cent, ninety per cent and one hundred per cent of the data entitlement, through SMS, email and mobile application if available. It is a data duty tied to a selected tariff. It does not track voice, SMS or the rupee value of your bill.
Regulation 20 requires the operator, immediately after you switch your handset on in the visiting country, to give you the tariff information and, if you have not subscribed to any roaming pack, to send an SMS warning about the possibility of significantly high charges at standard rates. If that SMS never arrived, ask in writing for the delivery record with the timestamp and the number it went to.
No. Chapter VI creates default off status, consent, activation information, tariff information, switch on warnings, data alerts, wrong zone warnings and an on demand short code. It does not set any ceiling on charges, and it prescribes no refund formula.
If you requested activation, the published tariff applies. Your remaining arguments are the information duties: whether you were told the applicable rates when you selected the tariff under regulation 19, whether you were warned on switching on under regulation 20, and whether you were told when you moved into an uncovered zone under regulation 22.
The 2024 quality of service regulations set the benchmark at 100 per cent of billing and charging complaints resolved within four weeks, with any credit, waiver or adjustment applied to your account within one week of resolution. Wrong roaming charges and charging for services provided without consent are both listed as billing and charging complaints.
Yes. In Vodafone Idea Cellular Ltd v Ajay Kumar Agarwal, decided on 16 February 2022, the Supreme Court held that section 7B of the Indian Telegraph Act, 1885 does not oust the jurisdiction of the consumer forum, and restored the consumer complaint.
No. TRAI states that the TRAI Act, 1997 does not envisage handling of individual consumer complaints by TRAI, and that a subscriber must use the two tier mechanism of the operator call centre and then the operator appellate authority.