TABLE OF

CONTENT
Executive
Summary 04

Introduction 05

Overview of the Smart

Metering Rollout in India 07

About the
Paper 08

Cyber Risks for Smart

Metering Infrastructure 10

Privacy Implications
of Smart Meter 12

Data Flow
Landscape 14

Challenges in Securing Data

Privacy in Smart Meters 16

Applicable Legislation for

Smart Meter Data Privacy 17

Learnings from International

Best Practices 18

Conclusion 21

Annexure I Recommended
Landscape 22
 EXECUTIVE
SUMMARY
India is undergoing a massive transformation in its utility management through Smart Meter
National Program (SMNP), launched under the Revamped Distribution Sector Scheme (RDSS).
The initiative aims to replace 250 million conventional meters with smart meters by 2025-26. As
of early 2025, over 2 crore meters have been installed, with tenders awarded for approximately
22 crore smart meters. These IoT- enabled devices use embedded sensors to monitor electricity,
water, and gas consumption in real time, transmitting data wirelessly to utilities and consumers
via networks like cellular (4G/5G), NB-IoT or RF signals. This eliminates the need for manual
meter reading, reducing human error and operational costs. Smart meters are also effective in
optimizing energy efficiency and reducing energy waste. However, smart meters face risks of data
breach and cybersecurity attacks. As we transition towards smart meters in India, it is imperative
that these risks are assessed, analyzed and addressed.

This paper on data privacy in smart metering discusses the nature and types of smart meter data
collection, its access, control and issues of consumer awareness and consent around it. The paper
also analyses applicable legislation for smart meters globally and delineates lessons for India from
the best practices that are prevalent internationally. At the brink of transition to smart meters in
India, the paper draws attention to data privacy and cybersecurity considerations which need to
be incorporated at each step. The paper recommends a multi-layered approach and strategies to
enhance the security of smart metering infrastructure, and provides recommendations for policy
makers, utilities, industry stakeholders and regulators.

The CII Core Group on Smart Metering, chaired by Mr. Suket Singhal, Group Chief Executive
Officer, Secure Meters and the Taskforce on Data Privacy on Smart Metering, headed by Mr. Rohit
Sharma, Head Cyber Security, Adani Power, provided valuable insights which facilitated the timely
completion of this study. Other members of the subgroup were Mr. Anurag Johri, MD & Lead
Utilities, Accenture, Mr. Abhishek Biswal, Head – Digital Services, Airtel, Dr. Jatin Patel, Director
(I/C), School of Information Technology, AI and Cyber Security, Rashtriya Raksha University, Ms.
Sanyogeeta Gaekwad, Director- Privacy, Privacient, Dr. Sumedha Ganjoo, InfoSec Lead (Privacy),
Secure Meters Limited and Mr. Abhinav, Policy Team, Secure Meters Limited.

04
 INTRODUCTION
Smart meters represent a significant advancement in how energy consumption is monitored
and managed. Beyond basic metering, these devices support detailed analytics like predictive
and preventive analysis by tracking energy production and consumption patterns. Some smart
meters integrate with building automation systems (BAS), allowing automated management of
heating, cooling, lighting, and other utilities based on real-time usage data. This capability is
particularly valuable for optimizing energy efficiency and reducing energy waste.

As part of this transformation, significant volumes of sensitive consumer data are collected,
stored, and transmitted by both public and private stakeholders, necessitating a robust data
privacy framework. Therefore, integration of smart meters into the power grid also introduces a
new set of cybersecurity challenges that need to be addressed.

The paper navigates through four sets of challenges including data privacy, cybersecurity
vulnerabilities, regulatory compliance challenges, data ownership and consumer rights.

SMART METERING DATA (IN CR)

2.43

19.79 11.4

Sanctioned Installed Awarded

SOURCE: RDSS Ministry of Power

As of early 2025, over 2 crore smart meters have been installed with tenders awarded for
approximately 22 crore smart meters. The rollout prioritizes electricity meters, operating largely
in prepaid mode, to enhance billing accuracy, reduce transmission and distribution losses, and
empowers consumers to track usage via apps or SMS.

States, like Bihar, Assam & Uttar Pradesh, are leading the adoption of smart meters, driven by
government targets and consumer engagement efforts. It is expected that by the year 2026
there will be full deployment of smart meters. This will boost efficiency for distribution companies
(Discoms) and support India’s sustainability goals.

05
 Y-o-Y Smart Consumer Meters Installation
1.6Cr 3Cr
1.4Cr
2.5Cr
1.2Cr

CUMULATIVE
2Cr
FY WISE

1Cr
80L 1.5Cr
60L
1Cr
40L
50L
20L
Ok Ok
0
7

5
9

4
2
8

-2
-1

-2

-2
-1

-2

-2
-2
-1
16

20
18

19
17

24
22

23
21
20

20

20
20

20

20

20

20
20
Sourc: National Smart Grid Mission - Ministry of Power, Government of India

06
 OVERVIEW OF SMART
METERING IN INDIA
Over the past decade, smart metering in India has progressed considerably, fuelled by technological
advancements, regulatory changes, and significant investments focused on modernizing the
power sector.
In 2021, the Ministry of Power introduced the Revamped Distribution Sector Scheme (RDSS),
committing around INR 3,037.58 billion (approximately £29 billion) over five years to support the
phased rollout of prepaid smart meter projects nationwide. The initiative aims to improve billing
and collection efficiencies, minimize distribution losses, and strengthen the financial stability of
distribution companies (DISCOMs).
In March 2025, the Central Electricity Authority (CEA) introduced draft amendments to metering
regulations to standardize and modernize the power grid. These proposed changes include revised
definitions for “Interface Meters” and mandatory adherence to Advanced Metering Infrastructure
(AMI) standards, with the goal of improving transparency and efficiency in metering practices.
The growth in demand for smart meters is projected to increase in the country, driven by greater
demand for accurate billing, efficient energy management, and improved consumer awareness.

Conventional Meters

Conventional
Manual billing
Meters
Residential/
Manual Collection
Industrial
the data
customer

Smart Meters

Residential/ Communiaction Communiaction

Industrial interface/ interface/
customer protocol protocol
Smart Gateway
Meters Database

Source: Al-Waisi, Z., & Agyeman, M. O. (2018). On the challenges and opportunities of smart
meters in smart homes and smart grids. Proceedings of the 2nd International Symposium on
Computer Science and Intelligent Control, 1–6. https://doi.org/10.1145/3284557.3284561
Figure shows the operation of conventional meters and smart meters.

07
 ABOUT
THE PAPER
The paper goes into the cybersecurity and privacy aspects of smart metering infrastructure and
its further implications on individual consumers and the broader grid infrastructure. This includes
identifying potential risks, examining legal and ethical concerns, and evaluating the mechanisms
in place to ensure secure, transparent, and ethical data management.

Data privacy and cyber security concerns are spread across the entire gamut of activities related
to smart meters. This includes collection of data and its usages, data storage and management,
data transmission and communication, third party involvement in handling consumer data and
mechanisms of data access control and alignment with regulatory frameworks.

The following are the themes of the paper:

Data Collection and Usage: Different types of data are collected by smart meters (e.g., consumption
data, voltage data, real-time energy usage, customer identifiers). The utilities use this data
for varied purposes such as billing, grid management, predictive maintenance and improving
operational efficiency. The frequency and granularity of data collection (e.g., daily, hourly, or real-
time) is also used differentially to infer consumer activities from it. The data collected includes
sensitive data such as personal information, location data, and energy consumption patterns that
may be misused, if not adequately protected.

Data Storage and Management: The data collected is stored, managed and processed by utilities,
third- party service providers, and vendors involved in smart metering. It is, therefore, important
to understand the use to which the collected data is put and the mechanisms in place for data
retention, archival, and destruction of the collected data. Further, the paper also covers types
of databases, cloud storage, or on- premises servers which are used to store the data and the
security measures they offer. It also goes into governance policies around data, particularly those
regarding access, use and sharing of consumer data.

Data Transmission and Communication: The technology used for transmitting data from the
smart meters to the utility (e.g., cellular networks, RF, powerline communication), security
measures for encrypting data during transmission and protecting it from cyber threats like
hacking, eavesdropping, or data breaches are also within the scope of this paper.

Third-Party Involvement: The role of third-party vendors, technology partners, and subcontractors
in handling customer data. The compliance of third parties with data protection laws and the
contractual obligations that bind them to confidentiality and data security requirements are also
significant factors that impact data privacy in smart metering.

Data Access and Control: The specificity of conditions under which utility staff, third-party
service providers and regulators have access to customer data and the mechanisms for customer
consent, data access control, and opt-out options for customers who wish to limit the sharing or
use of their data have also been studied.

08
Regulatory Framework and Compliance: The paper analyzes how smart meter data collection,
storage, and processing align with existing Indian data privacy regulations, such as India’s
Digital Personal Data Protection Act (DPDP Act) which was passed by the Indian Parliament on
August 11, 2023 ,The Information Technology (Reasonable Security Practices and Procedures and
Sensitive Personal Data or Information) Rules, 2011 and state-level regulations or guidelines for
data privacy specific to utilities and public sector entities. Alongside these regulations, the paper
also states the impact of international data protection regulations such as GDPR in the European
Union and the way it may impact Indian utilities, in case customer data is transferred abroad due
to involvement of international technology vendors.

Consumer Awareness and Consent: The paper explores information disseminated to the
consumers about the data that is collected, their rights to consent and the control that they
can exercise over their personal data. The paper also addresses the effectiveness of consumer
education programs to ensure that the customers understand the implications of smart meter
data collection.

These aspects of data privacy have already been acknowledged by the stakeholders. This paper
provides recommendations for further strengthening these mechanisms. Furthermore, smart
meters also face the challenge of cyber risks which poses a great challenge.

09
 CYBER RISKS FOR SMART
METERING INFRASTRUCTURE
As with any connected device, smart meters too are vulnerable to cyberattacks. The potential
threats include a range of issues such as:

Data Breach: Smart meters collect and transmit a large amount of data, such as energy usage
patterns, device status, location, and customer identity, which can reveal personal or business
information, habits, preferences, and behaviors. This data can provide detailed insight into a
household’s daily routine, habits, and lifestyle, which could be used by third parties for various
purposes such as targeted marketing or even criminal activities like burglary. Moreover, there
are concerns about the unauthorized sharing or selling of this data to third parties, including
energy suppliers, marketers, and government agencies, which can raise issues about the misuse
of personal data and erosion of privacy rights.

Data Integrity Compromise (Tampering / False Data Injection Attacks): If the data being
collected by smart meters is intercepted and tampered with, it can result in financial fraud, or
sabotage. For example, hackers could manipulate the data to inflate bills, alter demand response
signals, or create false data sets. False data can be injected into the smart metering infrastructure
to present an incorrect picture of electricity demand and manipulate the grid operations and
electricity markets.

Financial Fraud: Manipulation of metering data can be used to perpetrate large-scale financial
fraud in electricity billing. This can create an impact on the financial health of the distribution
companies and can adversely impact the entire sector.

Electricity Market Manipulation: Injection of false data into the smart metering infrastructure
can also be used to present an inaccurate picture of the electricity demand and skew the market
mechanism to benefit a few market-participants.

Service Availability disruption and Unauthorized Control Operations: Smart meters are
connected to the internet and the power grid, which exposes them to potential cyberattacks
that can exploit their vulnerabilities, such as weak passwords, outdated firmware, or unsecured
communication protocols. If hackers gain access to smart metering infrastructure, they can infect
them with malware, ransomware, or botnets, which can cause damage & disruption. For example,
hackers could remotely control the smart meters to switch them on or off, alter their settings and
cause black-out over a large area.

Power Blackout: Compromise of smart metering infrastructure can allow the attackers to cut-off
power to a large area thereby causing black-out.

Load Oscillation Attacks: Rapid Switch-ON and Switch-Off actions on multiple smart meters at a
pre- defined frequency can cause oscillations in the grid. If an attacker can compromise a fleet of
smart- meters, they can use these meters to introduce oscillations which can trip grid-elements
and result in de- stabilization of the grid.

Launchpad for Cyber Attacks and Denial-of-Service Attacks: A typical smart metering
infrastructure would contain millions of smart meters; In case Cyber attackers are able to
compromise these meters; they would have millions of intelligent devices at their disposal which
can be used as a launchpad for further cyber-attacks like DDoS (Distributed denial of Service).

10
Cyber Attacks on Grid Infrastructure: Smart metering systems are part of a complex and
interdependent energy infrastructure that relies on the coordination and communication of
multiple actors, such as utilities, grid operators, service providers, and customers. If a cyberattack
affects one or more components of the smart metering system, it can have cascading and
disruptive effects on the whole system, affecting its stability, reliability, and safety. For example,
a cyberattack could cause power outages, voltage fluctuations, frequency deviations, or physical
damage to the grid equipment.

Grid Destabilization: The secure operation of a smart grid is closely linked to state estimates
that accurately reflect the physical characteristics of the grid. However, a false data injection
attack (FDIA) can manipulate the process of state estimation by injecting malicious data into
the measurement data, ultimately causing the results of state estimation to deviate from secure
values and destabilizing the grid.

Ransomware: A cyber-attacker who gains control over smart metering infrastructure can extort
the utility for ransom to let them regain control and access data.

Hybrid Attacks: Unauthorized control operations and data manipulation can also be coupled
with other kinds of attacks such as fake news & disinformation campaigns to achieve political or
geo-political objectives.

Several attack vectors such as meter compromise can be executed through vulnerability
exploitation or cyber-physical tampering. MITM (Man in the Middle) attack and data replay attack
can compromise the network. Vulnerability exploitation in MDMS/ metering applications and
infrastructure can lead to Head- end Compromise. Rogue devices can launch attacks on smart
metering infrastructure by connecting unauthorized devices to the network. Using jamming signals
to disrupt smart metering infrastructure and using smart meters to launch a Denial of Service
(DoS) on other systems can also compromise the smart metering infrastructure. Exploitation of
application-level vulnerabilities of MDMS and other smart metering applications are other attack
vectors that need to be addressed to secure the integrity of smart meter infrastructure.

11
 PRIVACY IMPLICATIONS
OF SMART METER
The varying granularity of smart meter data can reveal different insights about consumer activities
and behavior. Smart meter data with a minute’s interval can detect most domestic appliances,
while half-hourly data can only infer occupancy information. Most smart meters currently being
installed worldwide log data hourly, half -hourly or at 15 min intervals. This can provide a strong
indication of occupancy but has less potential to currently reveal individual appliance use.

Information inferred from data

Mean Major Most
electricity appliance appliance
Occupancy
use identifiable identifiable

Quaterly Half-hourly 1 Minute 1 Second

Data Resolution
Low Highly

Privacy/Confidentiality Risk

Source: Zhang, X.-Y., Guo, P., Kuenzel, S., & Yin, C. (2024). Ethical considerations in Advanced Metering
Infrastructure Integration: A systematic review. Energy Strategy Reviews, 56.
https://doi.org/10.1016/j.esr.2024.101571

A data mining technology, called Non-Intrusive Load Monitoring (NILM), can extract the appliance
usage information from smart meter data with high degrees of accuracy. Based on smart meter
data and the NILM algorithm, information can be obtained on appliance usage information i.e.
the operational status of the household appliances, such as air conditioners, dishwasher, kettle,
washing machine, and refrigerator. It can also indicate whether the resident is present or away.
When the resident is away, most electronic appliances are turned off and few activities would be
detected (it should be noted that the refrigerator will continue to turn-on/turn-off automatically,
so non- refrigerator events can be used to determine presence/absence of the customer).
Real- time data about events that happen in the house, such as breakfast, lunch, dinner, parties,
showering, and playing video games are also traceable as are the sleep cycles of the residents.

12
 Source: Zhang, X., Watkins, C., Took, C. C., & Kuenzel, S. (2021). Privacy boundary determination of
smart meter data using an artificial intelligence adversary. International Transactions on Electrical
Energy Systems, 31(9). https://doi.org/10.1002/2050-7038.13020

Possible Privacy concerns for Consumers due to such mapping can include the following:

Planned Burglary and Physical Attacks: Burglary and attacks can be planned based on the
number of people in a particular household or a large neighborhood. A Malfunctioning smart
meter can be easily used as a pretext for entering a home for maintenance purposes.

Fingerprinting Power Consumption to Achieve Personal Profiling: Data analytics using data
mining algorithms on the energy consumption patterns captured by smart meters, can be used
to make inferences about household activity - from how many showers a person takes to when
they’re cooking dinner.

Targeted Advertising: Energy consumption patterns can be used to identify customer segments;
possible sales leads for products/services and poorly performing appliances in the household
which are target for possible replacement sales. Presence information will be valuable for a
telemarketing company as they will know if it’s a good moment to call a household.

Surveillance: It could open the potential risk of stalkers monitoring their victims’ activities and
behaviors inside their own home, gaining insight into their movements. Residents may also be
susceptible to monitoring by landlords and other family members. While it can help in monitoring
the usage of electricity it creates the scope for unwanted surveillance and breach of privacy.

13
 DATA FLOW
LANDSCAPE
To understand privacy and cybersecurity concerns in smart meters it is important to understand
the data flow. Based on data captured around consumption of electricity, power quality metrics
such as voltage fluctuations, outage detection and metadata including meter ID, timestamp and
location from smart meters installed at customer premises the following data flow landscape has
been mapped.

Smart Meter Data Flow Diagram (DFD)

Billing
System

Consumer
Portal

Smart Utility
MDMS
Meter Gateway
Regulators

Third-
Party

Storage Anonymization

Smart Meter Data Flow Diagram (DFD)

Data Flow in smart meters can be understood as beginning with smart meters being the source of
data. The flow can be summarized as follows: Smart Meters (Data Source) → Utility Data Gateway
(Transmission) → MDMS (Processing & Storage) →Billing System / Consumer Portal / Regulatory
Authorities (Access & Sharing) and Data Storage → Retention Policies → Anonymization/Deletion
(Data Lifecycle Management).
Each of the steps in the data flow can be elaborated to understand the participation of every
stakeholder in the process, from generating to storing the data. After the data is generated by
smart meters it is transmitted securely in accordance with the transmission protocols. These
protocols include Power Line Communication (PLC), RF Mesh, Wi-Fi, Cellular (4G/5G) and
encrypted transmission (TLS, AES-based security). The data is then stored at the utility centers
or cloud servers (Third-party providers). Hereafter, the data is processed and aggregated by the
Meter Data Management System (MDMS) and AI- based algorithms such as Non-Intrusive Load
Monitoring (NILM). This then helps in generating insights such as consumer energy consumption
trends, appliance usage patterns (NILM extraction) and provides predictive analytics for demand

14
forecasting. The data is accessible to consumers through mobile apps and web portals. It is also
available to the utility providers for billing and demand forecasting and helps grid operators
to ensure stability in power distribution. Further the data can also be accessed by the third-
party service providers for energy optimization services and to regulatory authorities for policy
compliance and audits. Data is stored for predefined periods of up to 2-5 years for billing records.
Compliance with privacy regulations including GDPR, DPDPA and other local privacy regulations
is a must. It is imperative that consumers should have the right to request deletion of their data
and that there is provision for automated deletion after the retention period.
The data flow of smart meters helps understand the possible interventions that are needed to
secure privacy and integrity of the data generated. This then brings us to the section on possible
concerns and challenges around data privacy and the vulnerability of data to cyberattacks which
need to be addressed in securing the smart meter infrastructure in India.

Challenges in Implementing Smart Meters

Financial challenges: High capex/operational expenditure & return on investment

Regulatory challenges

Cybersecurity risk

Interoperability issues and various changes in network & connectivity

Operational challenges mainly related to scalability and integrations with existing systems

Customer resistance to installing smart meter is also witnessed at multiple locations

15
 CHALLENGES IN SECURING
DATA PRIVACY IN SMART METERS
It is evident that unless addressed smart meters can be used to breach the privacy of the
consumers. As discussed earlier in the paper, these revolve largely around profiling and
surveillance. Collection of detailed consumer energy data beyond what is necessary for billing
or grid management. Storing and processing granular data for extended periods without proper
justification. Unauthorized third parties gaining access to smart meter data through data breaches
or cyberattacks. Utility employees misuse access privileges to monitor individual consumption
behaviors inferring personal lifestyle patterns, including sleep cycles, daily routines, and appliance
usage habits. Targeted advertising based on energy consumption patterns, leading to consumer
profiling without consent, all add to the challenges of managing data privacy.

Selling or sharing consumer energy data with third parties, such as advertisers or insurance
companies, without explicit consent of the consumers and the utilities leveraging consumption
data for targeted pricing models, potentially leading to unfair discrimination add to the
challenges. Failure to implement data protection measures such as lack of encryption during data
transmission, makes smart meter data vulnerable to interception. Also, poorly designed access
control mechanisms lead to unauthorized data leaks, making them susceptible to breaches.

Smart meter data, if compromised, can expose consumers to privacy violations and cyber-attacks
leading to complexities. The subject of cyber-attacks becomes more difficult to manage, as there
is a lack of uniform security protocols. Different jurisdictions impose varying cybersecurity
requirements, making compliance complex.

Ambiguity in data ownership between consumers, utility providers, and third-party analytics firms
and consumer rights to access and transfer smart meter data are often restricted by proprietary
data formats and platform limitations. Some jurisdictions require opt-in consent for data sharing,
while others operate on opt-out models, leading to confusion.

Regulatory compliance also poses a significant challenge. Varying global regulations (GDPR,
CCPA, DPDPA, etc.) create compliance difficulties for multinational utilities. Further, different
legal frameworks impose restrictions on international data flows, complicating energy data
sharing and analysis. Some regulations require data retention for billing purposes, while others
mandate early deletion to protect consumer privacy.

16
 APPLICABLE LEGISLATION FOR
SMART METER DATA PRIVACY
The most recent legislation in India on protection of data, The Digital Personal Data Protection Act
2023 (DPDPA) applies to smart meter data processing by entities operating in India. The DPDPA
Act states that smart meter data should only be collected and processed for legitimate purposes,
with explicit consent where applicable. It, therefore, tightens the purpose for which the data can
be used and the importance of seeking clear consent to put it to use. It states that data fiduciaries
and processors have obligations that utility companies are responsible for ensuring compliance with
security and privacy safeguards. The Act also covers in its purview cross-border data transfers. If
smart meter data is transferred outside of India, compliance with government mandated regulations
is mandated by the act. The inferences drawn from the collected data, particularly in the case of
aggregated analytics, must be managed through anonymization techniques. The Act also prohibits
retention of data beyond necessary durations.

There are several international pieces of legislation from which India stands to gain while addressing
the issues of data privacy and cyber security in smart metering. One such instance is that of The
General Data Protection Regulation (GDPR) applicable in the European Union. GDPR applies to any
entity processing personal data of individuals in the European Union, including smart meter data
collected by utility providers. Some of the key provisions of this act include lawful basis for processing
(Article 6) which states that utilities must justify data collection under contractual necessity, legitimate
interest, or consumer consent. The provision on special categories of data (Article 9) states that
energy consumption data is not explicitly classified as sensitive but that granular insights can indirectly
reveal sensitive behavioral information, therefore warranting stricter safeguards. The consumers must
therefore be informed about the collection, purpose, and storage duration of smart meter data under
Article 12-14 of the said regulation. The utilities should only collect the necessary data and limit its
usage to stated purposes and under the Article 15-22 of the regulation consumers have the right to
access, rectify, and erase their smart meter data and object to automated processing. The regulation
also contains provisions for strong encryption and cybersecurity measures to prevent unauthorized
access to smart meter data. Article 32- 34, mandates that any breach must be reported well within
72 hours. Furthermore, if smart meter data is transferred outside the European Union, appropriate
safeguards (Standard Contractual Clauses, adequacy decisions) must be put in place as per Articles
44-50 of the said regulation.

The UK GDPR has been applicable following Brexit. The UK GDPR mirrors the GDPR in the European
Union but includes specific national provisions under the UK Data Protection Act 2018. Smart meter data
is classified as personal data under the UK GDPR. Strict access control mechanisms and anonymization
techniques are in place to mitigate data privacy risks. The UK Information Commissioner’s Office
(ICO) oversees compliance and enforcement. Consumers have enhanced rights to access the data and
are allowed to port their smart meter data under Open Data policies.

The U.S. federal and State Laws constitute the Federal Energy Regulatory Commission (FERC)
guidelines. According to this legislation, smart meter data falls under critical infrastructure information.
Strict cybersecurity measures are in place to protect consumer data from unauthorized access. Several
state level privacy laws are in place to protect the integrity of data. The California Consumer Privacy
Act (CCPA) which grants consumers the right to access, delete, and opt out of the sale of their smart
meter data requires businesses to disclose data collection practices transparently. The Colorado
Privacy Act (CPA) & Virginia Consumer Data Protection Act (VCDPA) classifies smart meter data
under personal information. According to this legislation, consumers can opt out of data processing
for targeted advertising.

The Australia Privacy Act 1988 and Consumer Data Right (CDR) which governs energy sector data,
including smart meter data gives consumers right to access and share their energy consumption
data with third parties for better energy management. According to the Australian Privacy Principles
(APPs), data collection should be fair, lawful, and necessary for utility services. Consumers must be
informed about data collection and sharing practices. Strict security measures are required to prevent
data breaches

17
 LEARNINGS FROM
INTERNATIONAL BEST PRACTICES
Several countries across the world have embraced smart metering over the past two decades.
There is a wealth of experience and good practices related to data privacy and cyber security
emanating out of these initiatives. This section captures few of the good practices that might be
replicated in India.
Encryption and Secure Communication Protocols: Across the globe, leading smart meter
systems implement end-to-end encryption to secure communication channels between smart
meters, the utility infrastructure, and consumers. For example, in Europe and North America,
smart meters are commonly configured with AES (Advanced Encryption Standard) protocols
for data transmission, ensuring that sensitive consumption data cannot be intercepted or
manipulated by cyber attackers.

Recommendations:
India can adopt similar encryption standards to secure the data flows between the smart
meter and utility providers. Utilizing AES-256 encryption would provide robust security for
data at rest and in transit.
Integrating secure communication protocols like TLS (Transport Layer Security) for data
transmission and VPN (Virtual Private Networks) for remote access would enhance overall
system security.
Multi-Layered Authentication and Access Control: Countries like the United States and
Germany have set a strong precedent by requiring multi-factor authentication (MFA) and
role-based access control (RBAC) for any personnel accessing smart metering systems. This
ensures that only authorized users can view or manipulate sensitive data, reducing the risk
of insider threats and unauthorized access. Implementing multi-layered authentication
for both utility providers and consumers is crucial. Utilizing biometric identification, one-time
passwords (OTPs), and secure access tokens would help ensure that only legitimate users
have access to critical metering data.
For utility providers, role-based access should be implemented to restrict access based on
user responsibilities and clear security policies, thus preventing any potential misuse of
privileged access.
Data Minimization and Consumer Consent: In Europe, particularly under the General Data
Protection Regulation (GDPR), the principle of data minimization is a core practice, where
only the minimum amount of personal data necessary for operation is collected. Additionally,
consumers must provide explicit consent before their data is used, and they have the right
to withdraw that consent at any time. India’s Digital Personal Data Protection Act (DPDPA),
2023, lays down that similar principles of data minimization and consumer consent must be
implemented for smart meter data. Data collection should be limited to what is necessary for
billing and grid management, and customers should be informed about the data being
collected.
Utilities should develop clear consent forms that outline the types of data being collected, the
purpose of collection, and the duration of data retention, ensuring transparency in the process.
Regular Security Audits and Penetration Testing: Leading countries have instituted a
practice of regular security audits and penetration testing to identify vulnerabilities in the
smart metering infrastructure. For example, in the UK, smart metering systems undergo
annual security assessments conducted by independent third parties, ensuring that any
potential weaknesses are addressed before they can be exploited. India should enforce the
requirement for regular penetration testing and security audits for all smart metering
infrastructure, including the IoT devices themselves, communication networks, and the
backend systems used by utilities.

18
 Security Certifications should be established for vendors involved in smart metering solutions,
ensuring compliance with global security standards (e.g., ISO 27001, NIST Cybersecurity
Framework).
Real-Time Monitoring and Intrusion Detection Systems (IDS): Countries, like Japan and South
Korea, have implemented real-time monitoring systems that use intrusion detection systems
(IDS) and network traffic analysis to detect suspicious activity. These systems continuously
scan the network for anomalies and potential cybersecurity threats, such as unauthorized
access attempts or unusual data traffic. India can replicate this practice by incorporating
real-time monitoring and anomaly detection systems within its smart metering infrastructure.
By leveraging AI-driven intrusion detection systems, utilities can quickly identify and respond
to cybersecurity incidents, protecting both consumer data and grid security.
Continuous System Health Checks and real-time diagnostics should be mandated as part
of the maintenance protocols to ensure that smart meters and their supporting infrastructure
always remain secure.
Consumer Education and Data Transparency: In countries, like Canada, the Consumer
Privacy Protection Act requires utilities to actively engage with customers and educate them
about the types of data being collected, the security measures in place, and their privacy
rights. Additionally, consumers are provided with easy access to their own data, enabling them
to make informed decisions about how it is used. Indian utilities should develop comprehensive
consumer education programs that explain how smart meters work, the data they collect,
and the privacy measures in place. This will help foster trust and transparency with consumers.
To promote transparency and consumer empowerment, utilities should offer consumers
access to their own energy data, giving them the ability to monitor their consumption and
control how their data is shared.
Compliance with National and International Standards: Globally, many countries adhere
to national and international standards for data privacy and cybersecurity. For instance, the
EU Cybersecurity Act and ISO/IEC 27001 are key standards followed by utilities worldwide to
establish comprehensive cybersecurity protocols for critical infrastructure. India should ensure
that the implementation of smart metering systems complies with both national standards
such as the Indian Cyber Crime Coordination Centre (I4C) guidelines and international
standards such as ISO/IEC 27001 and NIST Cybersecurity Framework.
Government regulations under the National Cyber Security Policy and DPDP Act, 2023
must be updated and enforced to align with global best practices, ensuring that smart
metering systems meet the highest standards of security and privacy protection.

Strategies to Implement Best Practices

To ensure successful implementation, India can integrate these global practices into its smart meter
policies, under NSGM and RDSS, while also leveraging the Digital Personal Data Protection Act.
Addressing the diverse needs of urban and rural areas with customized encryption, authentication,
and privacy measures, along with consumer education, will strengthen the overall system. States,
like Bihar, Uttar Pradesh, West Bengal, Gujarat and Karnataka, can serve as pilot regions to set
the stage for nationwide adoption, while learning from the UK’s encryption, Germany’s access
controls, and the EU’s privacy standards to build a resilient, trusted smart grid ecosystem.
To address these cybersecurity and privacy risks, a multi-layered approach is necessary. The
following strategies can help enhance the security of smart Metering Infrastructure:
• Physical Security Measures: Physical security measures in design to prevent tampering.
• Encryption: Use of strong encryption methods to protect data in transit and at rest.
Implementing robust encryption protocols ensures that the data transmitted between smart
meters and utility companies is protected from interception and tampering. Encryption helps
maintain the confidentiality and integrity of consumer data.

19
 Authentication: Strong authentication measures in smart metering infrastructure to prevent
unauthorized access and rogue devices. Strong authentication mechanisms, such as multi-
factor authentication, can prevent unauthorized access to smart meters and the networks
they connect to. Access control measures should also be implemented to restrict access to
sensitive data and systems based on user roles and responsibilities.
Software Updates: Regular software updates should be provided to fix vulnerabilities and
improve security. Ensuring that smart meter software is regularly updated with the latest
security patches is critical in defending against known vulnerabilities. Utility companies
should establish procedures for timely updates to protect against emerging threats.
Jamming-Prevention Mechanism: can be used to protect the smart metering infrastructure
from DoS attacks.
Network Security: Analysis of network traffic can be used to detect any possible intrusion in
the smart metering network, like the intrusion detection systems used in the IT network.
Secure network architectures, including firewalls and intrusion detection systems, can help
protect smart meter networks from external threats. Network segmentation can also limit the
impact of a cyberattack by isolating critical systems from less secure areas of the network.
Employee Training: Personnel involved in operations and maintenance of smart metering
infrastructure should be trained in security best practices to prevent social engineering
attacks and other security breaches.
Consumer Awareness: Educating consumers about the importance of cybersecurity and the
role they play in protecting their smart meters is essential. Consumers should be encouraged
to use strong passwords and to report any suspicious activity related to their energy accounts.

Recommendations to Ease Current Bottlenecks about Data Privacy

in Smart Meter Devices
To ease current bottlenecks in smart meter data privacy, a collaborative approach between
government agencies, DISCOMs, technology vendors, and consumers is essential. A robust
combination of regulatory clarity and compliance framework, technical safeguards and data
protection measures, consumer education, and centralized oversight will enhance trust, security,
and efficiency in smart metering systems.
Implement dedicated and lean data privacy governance structure across the smart meter
landscape.
Deploy dedicated resources for implementing data privacy controls for smart meter, including
for DPO, data privacy professionals, etc.,
Budget provisioning for implementing Privacy Enhancement Technologies (PET) across
smart meter landscape.

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 CONCLUSION

The integration of smart meters into the energy grid presents both significant opportunities and
challenges. While these devices offer numerous benefits in terms of efficiency and consumer insight,
they also introduce new cybersecurity risks that must be carefully managed. By implementing
robust security measures and staying abreast of emerging technologies, utility companies can
protect their smart meter networks and ensure the continued reliability and safety of the energy
grid. As the world becomes increasingly connected, the importance of cybersecurity in smart
meters will only continue to grow, making it a critical area of focus for the future of energy
management.

As India deploys smart metering systems across the country under initiatives, such as the
National Smart Grid Mission (NSGM) and Revamped Distribution Sector Scheme (RDSS), it is
essential that data privacy and cybersecurity considerations are incorporated at every stage of
the implementation process. Drawing upon global best practices, India can establish a robust
framework that ensures both the protection of consumer data and the security of its critical
grid infrastructure. By adapting these practices to the specific regulatory, technological, and
consumer contexts of India, the country can lay the foundation for a secure, trustworthy, and
efficient smart metering ecosystem.

21
 ANNEXURE 1 –
RECOMMENDED LANDSCAPE
For Policymakers:
Regulatory Framework: Establish clear policies and mandates for smart meter deployment in
residential, commercial, and industrial sectors.
Incentives & Subsidies: Provide financial incentives for smart meter adoption to accelerate dep
loyment.
Data Privacy & Security Standards: Implement strict cybersecurity and data protection
regulations.
Interoperability Standards: Promote open communication protocols to ensure compatibility
across different meter manufacturers and networks.

For Regulators:
To ensure compliance and efficiency in energy and power sector infrastructure projects:
Adhere to Key Regulations: Align all projects with the Electricity Act, 2003 for legal
compliance in generation, distribution, and transmission.
Implement Energy Efficiency Measures: Follow the Energy Conservation Act, 2001 to integrate
energy-efficient technologies and practices.
Regulatory Approvals & Compliance Audits: Conduct regular audits and obtain necessary
clearances from regulatory bodies to ensure adherence to national standards.
Promote Renewable Integration: Align projects with government policies on renewable
energy to support sustainability goals and net-zero commitments.

For Utilities:
Network Reliability: Invest in robust communication infrastructure (e.g., LPWAN, NB-IoT, 5G)
to ensure uninterrupted smart meter connectivity.
Real-Time Data Utilization: Leverage smart meter data for demand forecasting, load
balancing, and outage management.
Consumer Engagement: Develop user-friendly platforms (apps, dashboards) to provide real-
time energy usage insights.
Operational Cost Reduction: Optimize workforce allocation by reducing manual meter
readings and billing errors.

For Industry Stakeholders (Manufacturers, Technology Providers, and Service Providers):

Innovative Solutions: Develop smart meters with enhanced functionalities like AI-based
analytics and remote control features.
Integration with Smart Grids & Automation: Ensure compatibility with IoT-enabled building
automation and energy management systems.
Security & Compliance: Adhere to global security standards (ISO, IEC) and collaborate with
regulators on best practices.
Scalability & Affordability: Develop cost-effective solutions to ensure widespread adoption
across different market segments.

22
The Confederation of Indian Industry (CII) works to create and sustain an environment conducive
to the development of India, partnering Industry, Government and civil society, through advisory
and consultative processes.

CII is a non-government, not-for-profit, industry-led and industry-managed organization, with

around 9,000 members from the private as well as public sectors, including SMEs and MNCs,
and an indirect membership of over 365,000 enterprises from 294 national and regional sectoral
industry bodies.

For more than 125 years, CII has been engaged in shaping India’s development journey and works
proactively on transforming Indian Industry’s engagement in national development. CII charts
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building and networking on key issues.

Through its dedicated Centres of Excellence and Industry competitiveness initiatives, promotion of
innovation and technology adoption, and partnerships for sustainability, CII plays a transformative
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to identify and execute corporate citizenship programmes across diverse domains including
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and sustainable development, to name a few.

For 2024-25, CII has identified “Globally Competitive India: Partnerships for Sustainable and
Inclusive Growth” as its Theme, prioritizing 5 key pillars. During the year, it would align its initiatives
and activities to facilitate strategic actions for driving India’s global competitiveness and growth
through a robust and resilient Indian industry.

With 70 offices, including 12 Centres of Excellence, in India, and 8 overseas offices in Australia,
Egypt, Germany, Indonesia, Singapore, UAE, UK, and USA, as well as institutional partnerships
with about 300 counterpart organizations in almost 100 countries, CII serves as a reference point
for Indian industry and the international business community.

For More Details, Please Contact:

Conference Sponsorship & Exhibition & B2B Delegates

Country Partnership Meetings

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