Roaming Bill Shock? It Should Have Been Off by Default

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 people assume, and what the regulation says

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

The rule, and where it lives

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.

Six duties, and the exact moment each one falls due

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.

The alert you are owed is not the one you expect

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.

  • It is a data duty. Voice minutes and outgoing SMS get no percentage ladder.
  • It measures a data entitlement, so it needs a selected tariff that contains an entitlement. Roam with no pack and there is no denominator to take a percentage of.
  • It says nothing about money. No rupee threshold, no running bill alert, no cut off.

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.

What Chapter VI does not do

  • No cap. Nothing in it limits what a roaming session may cost. It compels default off status, consent and information, and stops there.
  • No automatic waiver. There is no penalty payable to you, and no formula for a refund.
  • If you asked for it, you owe it. Once you requested activation and used the service, the published tariff applies whether or not you understood it.
  • A missing alert is evidence, not a discharge. It supports a deficiency of service complaint. It does not by itself cancel the bill.

Before you fly: the eight line checklist

  1. Get your roaming status in writing. Ask the operator to confirm by SMS or email whether roaming is active on your number, and from what date. Keep the message.
  2. If it is already active and you never asked, say so now, in writing. A dated complaint before the trip is worth far more than a memory after the bill.
  3. Ask for the regulation 23 short code so you can pull your tariff and your billed amount from inside the destination country.
  4. Note the exact countries your pack covers. Regulation 22 exists precisely because zone drift catches people out. A pack for one country is not a pack for its neighbour.
  5. Confirm the alert channel. Alerts go to SMS, email and the app “if available”. If your registered email is a dead college address, fix it now.
  6. Know the data toggle. Under regulation 10B of the same regulations, no operator may activate or deactivate data service on your connection without your explicit consent, and every cellular operator must run toll free short code 1925 for activation and deactivation requests.
  7. Turn off data roaming in the handset until the pack is confirmed live. The regulation protects your account. Handset settings protect your first hour on the ground.
  8. Save the pre departure screenshots. Pack name, validity, inclusions, countries. Your complaint will be built on these.

A worked example

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.

  • Regular monthly plan and rental: ₹3,200
  • Roaming pack he actually chose: ₹4,999
  • Data charged at standard rates in the country the pack did not cover: ₹53,201

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.

Common mistakes

  • Arguing about the rate instead of the consent. The tariff is filed and published. Your leverage is regulation 17 and the regulation 20 and 22 warnings, not the price per megabyte.
  • Complaining only on the phone. No docket number means no clock, and no clock means no appeal.
  • Quoting the percentage alerts when you had no pack. Regulation 21 needs an entitlement. Claim it where it does not apply and you hand the operator an easy answer.
  • Waiting past the appeal window. The appeal to the appellate authority runs from the expiry of the complaint time limit, not from the date you get annoyed.
  • Paying the whole bill and arguing later. Once paid in full, a waiver becomes a favour rather than a remedy.
  • Trying to file an RTI against a private operator. Airtel, Jio and Vi are not public authorities under the RTI Act, 2005.

The bill has already arrived: five rungs

  1. Raise a written billing complaint at the Complaint Centre and capture the docket number. Under the Telecom Consumers Complaint Redressal Regulations, 2012, the Complaint Centre must register the complaint, allot a docket number, and SMS you that number with the time in which it is likely to be resolved. TRAI classifies “wrong roaming charges” and “charging for services provided without consent” as billing and charging complaints, so use those words.
  2. Hold the operator to four weeks. Under the Standards of Quality of Service of Access and Broadband Service Regulations, 2024, in force from 1 October 2024, the benchmark is that 100 per cent of billing and charging complaints are resolved within four weeks, and any credit, waiver or adjustment arising from that resolution reaches your account within one week of resolution. Treat it as the yardstick you quote, not as a personal guarantee.
  3. Appeal to the operator appellate authority. No fee is charged for the appeal. It must be filed within thirty days after the complaint time limit expires, and the appellate authority may still entertain it up to three months after that for sufficient cause. TRAI states that an appeal can also be registered by dialling toll free 198 and that the time limit for disposal is 39 days from the date of filing. A TRAI direction dated 12 March 2026 now requires every access provider, unified licensee and internet service provider to display a clearly visible “Customer Care” tab on the landing page of its website and the home page of its app, carrying the appellate authority name, designation, address, email, phone and the appeal time limits.
  4. Go to the consumer commission. In Vodafone Idea Cellular Ltd v Ajay Kumar Agarwal, Civil Appeal No 923 of 2017, decided on 16 February 2022, the Supreme Court held that the arbitration provision in section 7B of the Indian Telegraph Act, 1885 does not oust the consumer forum, and that the District Forum had jurisdiction to entertain and try the complaint. Consumer complaints against telecom operators are maintainable.
  5. Do not wait on the regulator. TRAI states that the TRAI Act, 1997 does not envisage handling of individual consumer complaints, and that the route is the two tier mechanism of the call centre and the appellate authority.

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.

Where RTI actually fits

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.

FAQ

Is international roaming really off by default on every Indian SIM?

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.

What exactly are the roaming alert thresholds?

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.

Nobody warned me when I landed. Is that a breach?

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.

Does the regulation cap my roaming bill?

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.

I did request activation and still got a shock bill. Where do I stand?

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.

How long does the operator have to fix a billing complaint?

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.

Can I take my mobile operator to a consumer commission?

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.

Will TRAI refund my money if I complain to it?

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.

Sources

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