In submissions to TRAI’s consultation on the proliferation of public Wi-Fi networks, COAI, Bharti Airtel, VIL, and Reliance Jio argued that India differs fundamentally from countries where public Wi-Fi has become a major connectivity layer. Instead, they said mobile broadband has already emerged as the primary means of internet access for most users.
COAI argued that the “need for public Wi-Fi networks has substantially diminished“, while Airtel described India as an “overwhelmingly mobile-first market“. Vodafone said public Wi-Fi should be viewed through the “prism of scale, timing, relevance and use-case in Indian market”, while Jio contended that although public Wi-Fi retains some value, “the answer lies beyond regulatory interventions“.
Despite differences in emphasis, the submissions largely converged on one point: public Wi-Fi’s biggest challenge is not regulation, but consumer demand.
‘Public Wi-Fi has lost relevance’: COAI’s submission takes a strong position against further public Wi-Fi expansion. The industry body argues that affordable mobile broadband has made dedicated public Wi-Fi infrastructure increasingly unnecessary. According to COAI, consumers prefer mobile data because of its “cost-effectiveness, convenience, and enhanced security”.
The association repeatedly frames India’s connectivity story as a market success. It notes that broadband subscribers have grown from 137 million in 2015 to more than one billion in 2025, while data prices have fallen sharply and monthly consumption has surged.
As a result, COAI argues that “the case for large-scale Public Wi-Fi expansion in India is significantly weakened” and that “Public Wi-Fi has lost its relevance”. The submission also highlights operational barriers such as “discovery, authentication requirements, and security concerns”, arguing that these have contributed to persistently low adoption.
Vodafone says India is not Europe or South Korea: VIL advances a similar position but spends considerably more time arguing that international public Wi-Fi models do not apply to India.
The operator says public Wi-Fi may be useful in “high-footfall, indoor environments, airports, railway stations, shopping malls”, but insists policymakers should evaluate the issue through the “prism of scale, timing, relevance and use-case in Indian market”.
According to Vodafone, the key challenge is that India already enjoys some of the world’s cheapest mobile broadband. The company argues that many foreign public Wi-Fi programmes emerged because mobile data remained expensive, whereas India presents an “entirely inverted market reality“.
The submission warns of “deep structural misalignments between the Public Wi-Fi model and the revealed preferences of Indian consumers”. Consequently, Vodafone argues that policymakers should “study and monitor, not intervention from Government in shape of policy measures”. The company also cautions against copying international examples, saying that the “direct replication of global frameworks” is “entirely unfeasible” in the Indian market.
Airtel says markets should decide Wi-Fi’s future: The operator repeatedly describes India as an “overwhelmingly mobile-first market” where mobile networks already serve as “the primary access point to the digital economy”.
Like COAI and Vodafone, Airtel argues that weak public Wi-Fi adoption reflects consumer preferences rather than regulatory shortcomings. “These outcomes are not ‘failures’ to be corrected via regulation,” Airtel writes. Instead, they are “the natural result of rational user preferences and market economics”.
Jio says public Wi-Fi still has a role: Jio broadly agrees with the industry’s concerns but adopts a noticeably less sceptical position on public Wi-Fi itself. “Public Wi-Fi does have a role to play in ensuring that all Indians are always adequately connected,” the company says.
The operator points to railway stations, bus terminals and cricket stadiums as locations where large crowds can overwhelm conventional connectivity arrangements. However, Jio also argues that public Wi-Fi cannot succeed without broader improvements in fixed broadband infrastructure.
The company says any effort to expand public Wi-Fi “needs to be preceded by the steps to deliver the availability of fixed networks”. Jio further argues that public Wi-Fi’s commercial challenges stem from market realities rather than regulatory barriers. According to the company, users lose interest once they have to pay for Wi-Fi, while cheap mobile data has reduced the incentive to seek out hotspots.
PM-WANI arrived too late: Jio’s sharpest criticism concerns the PM-WANI model itself. The company argues that policymakers attempted to replicate the success of Public Call Offices (PCOs), but did so after market conditions had already changed.
“The PDOs could have been useful in 2G-3G era of mobile services,” Jio writes. However, the framework was introduced when “4G data was ubiquitous” and data prices had already fallen to around Rs 10 per GB.
Jio notes that PCOs flourished because telecom connections were scarce and expensive, but disappeared as mobile penetration increased. It draws a similar comparison with cyber cafés, which declined once affordable internet access became widely available. According to the company, “the low-cost mobile data availability has led to the failure to take off of the model”, and the continued rollout of 5G is further reducing the utility of public hotspots.
Operators oppose Wi-Fi subsidies and DBN funding: COAI argued that telecom operators contribute the overwhelming majority of the Digital Bharat Nidhi (DBN) corpus and “should not be required to fund, through their levies, a competing ecosystem that operates without equivalent obligations.”
Jio echoes this concern. It warns against a “structurally asymmetric competitive landscape” in which operators remain subject to spectrum costs, licence fees and rollout obligations while competing against subsidised alternatives.
Airtel likewise argues that public funding instruments should focus on “bridging genuine coverage gaps” rather than supporting public Wi-Fi-specific initiatives. Vodafone takes a broader view, arguing that intervention may be harmful when “competitive private markets are efficiently delivering outcomes”. Across the submissions, operators repeatedly argue that any incentives aimed at improving broadband access should be technology-neutral and available across connectivity platforms.
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