TRAI TCCCPR and AI calling: what the rules require

The Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) are TRAI's rules for every commercial call and SMS in India, and they apply to an AI voice agent exactly as they apply to a telecaller. The business being promoted must be registered on a DLT platform. Promotional calls must come from the 140 number series through a registered telemarketer. Customer preferences and consent decide who may be called. And TRAI's Third Amendment, notified on 18 September 2026, requires calls placed by software to be declared to the operator in advance once it takes effect. This is the position as of September 2026.

What the TCCCPR is

TRAI issued the regulations on 19 July 2018 (PDF), opens in a new tab. They repealed the 2010 regulations and have been in force since 28 February 2019. A commercial communication is any call or message whose primary purpose is to advertise or solicit business for goods, services, or a business or investment opportunity. The definition adds that it does not matter whether the goods, services or land offered actually exist. A call about a 3 BHK in a new tower is squarely inside.

The system runs on distributed ledgers kept by the telecom operators: separate registers for headers, content templates, customer preferences, consents and complaints. That is where "DLT" comes from.

The regulations have been amended three times, first in December 2018. The Second Amendment of 12 February 2025 (PDF), opens in a new tab rewrote the complaint and penalty machinery. The Third Amendment of 18 September 2026 (PDF), opens in a new tab deals with automated calling. It comes into force in stages after its publication in the Gazette: most provisions 30 days after, the A2P declaration and a few others at 60 days, and the appeal mechanism at 90 days.

Who the regulations apply to

Three kinds of party.

Access providers. Jio, Airtel, Vi, BSNL and the rest. Most obligations in the text are theirs: running registrations, scrubbing lists against preferences, handling complaints and acting against senders. TRAI can impose financial disincentives on an operator that fails.

Senders. The definition is deliberately wide. It covers whoever owns the number or header used, whoever made or caused the call, and the person dealing with the goods, services, land or property being offered. A developer whose project is pitched is a sender even when an agency or a software platform does the dialling. On DLT, the sender registers as a principal entity.

Telemarketers. Entities that deliver, aggregate or scrub commercial communication. A registered telemarketer holds a registration with an operator. Since the 2025 amendment, any commercial communication from a sender who is not registered with an operator is unsolicited commercial communication (UCC) by definition, whatever the customer's preferences.

DLT registration

Registration happens on the operators' DLT portals. TRAI's advice to senders sets out the steps: register as a principal entity, then register headers, content templates and consent templates. Headers and templates matter most for SMS. For voice, the identity that matters is the calling number and the series it comes from.

The 2025 amendment made registration harder to fake. Operators must physically verify the entity, authenticate its authorised person biometrically and link it to a unique mobile number. Senders and telemarketers must self-certify their details, headers and templates every year, or be suspended automatically.

Number series: 140, 1600 and 1601

Commercial communication may only use registered headers or numbers from the special series assigned for it. As of September 2026:

• 140 carries promotional calls. TRAI's quarterly report of 4 August 2026 (PDF), opens in a new tab says calls from 140 numbers are checked against the customer's preferences before delivery.
• 1600 carries service and transactional calls from banking, financial services, insurance and government. TRAI's direction of 19 November 2025 (PDF), opens in a new tab made it mandatory for entities regulated by RBI, SEBI and PFRDA, in phases between January and March 2026.
• 1601 is a newer series, allotted by DoT, for service and transactional calls from other sectors. TRAI's direction of 10 August 2026 (PDF), opens in a new tab opens it first to utilities, courier and logistics. Real estate is not in that first phase.

For a developer today, promotional calls go on 140. An ordinary 10-digit mobile number is not a commercial calling line. TRAI's direction of 13 August 2024 (PDF), opens in a new tab told operators to stop promotional calls from unregistered senders using SIP, PRI or other resources, and to disconnect and blacklist offenders for up to two years.

The designated series also carry a protection. Under regulation 34A, added in 2025 and rewritten in 2026, call-management apps may not blanket-block or spam-tag calls from 140, 1600 or 1601 numbers.

Consent and preferences

A promotional call may reach a customer who has not blocked that category in the preference register, the DND register still widely called the NCPR, or one who has consented. Real estate is its own category, so a buyer can block property calls and keep others. Explicit consent, acquired digitally and registered through the operator's consent system, overrides a block for that sender.

Three rules matter on a sales floor:

• Enquiries last seven days. The Third Amendment rewrites "relationship", the basis for inferred consent. An enquiry the customer made in writing or by digital means counts only within the seven days before the call, and the sender must keep it in verifiable form. An application for a product or service counts for three months.
• Revoked consent stays revoked. Under the 2025 amendment, a sender may ask a customer who revoked consent for it again only after 90 days.
• TRAI consent is not data-protection consent. The Third Amendment says the regulations do not exempt a sender from the Digital Personal Data Protection Act. We cover that in the DPDP Act for sales teams.

How the register works, and why no vendor can scrub against it for you, is in DND and the NCPR explained. Preferences also include hours of the day, which we unpack in calling hours for commercial calls in India.

Complaints and penalties

A customer can complain through 1909, the TRAI DND app, the operator's app, website or email, within seven days of the call. Against a registered sender, the complainant must have registered preferences. Against an unregistered one, there is no such condition.

For unregistered senders the thresholds are fixed in the text. Complaints from five or more unique recipients in ten days lead the operator to suspend the resources used and investigate. A confirmed first violation bars outgoing services on all the sender's telecom resources, PRI and SIP trunks included, for 15 days. A repeat means a year's disconnection across all operators, blacklisting, and blocking of the devices used. The Third Amendment adds a faster trigger: three complaints in ten days when the operators' AI systems have also flagged the sender's number.

For registered senders, the operator checks whether the regulatory pre-checks were carried out before delivery and acts against the defaulting entity if they were not.

The machinery is used. In April to June 2026, TRAI's quarterly report (PDF), opens in a new tab counted 10.85 lakh UCC complaints, 1,37,053 telecom resources barred for 15 days, 46,786 disconnected for a year and 263 senders blacklisted.

What changed in 2025 and 2026

• February 2025. The Second Amendment. Unregistered senders' communication became UCC by definition. Senders must tell their operator in advance, in writing, when they use auto-dialled or robo calls. Complaints got a seven-day window and the thresholds above.
• November 2025. The 1600 series became mandatory, in phases, for entities regulated by RBI, SEBI and PFRDA.
• August 2026. The 1601 series opened for utilities, courier and logistics.
• September 2026. The Third Amendment. It defines an A2P call as one initiated by an application, software system or automated platform without direct human dialling, "including using autodialling, robo-calls and/or pre-recorded/artificial voice technologies". Once that part takes effect, sixty days after publication in the Gazette, every sender must declare A2P calling to its originating operator in advance, with the calling-number ranges it will use, and the declaration is recorded on DLT. An undeclared A2P call is treated as UCC. The terminating operator may charge the originating operator up to 5 paise a minute for A2P calls, except calls from the designated series. TRAI's press release of 18 September 2026 (PDF), opens in a new tab summarises the rest.

One draft is worth watching. In September 2026 the Central Consumer Protection Authority circulated draft guidelines on pesky and promotional communication. They would require a business using an AI-generated voice to say so at the start of the call. They are a draft, not law.

Where AI calling raises the stakes

The rules are the same for a person and a machine. The failure modes are not.

• Scale. A telecaller who dials from the wrong number makes one mistake an hour. An agent dialling from an unregistered line makes it on every call, and complaints from five people are enough to start action.
• Opt-outs, in the words people actually use. "Dobara call mat karna" (don't call again). "ફોન ના કરતા" (phone na karta: don't phone). "Remove my number." An agent has to catch them in each language it speaks, and act on them the moment they are said. A CRM status of "Not interested" is not an opt-out: it is something a dialler reads, and the lead can come back round the queue.
• The declaration. Under the Third Amendment, the operator must know in advance that software is placing the calls, and from which numbers. That is a sender's filing, not a feature.
• Evidence. A complaint names a number and a date. Having the recording and transcript of that call, against the lead, is how a sender shows what was actually said.

What software enforces, and what the business must register

This is the split that decides whether a campaign is compliant. BlackWolf enforces the first column on every call. The second column is registrations and contracts. No software can hold them for you.

Naming your company at the start of the call is not in the first column: each agent's opening is scripted with you, and the platform does not check it on every call. Listen for it on your test calls.

A platform can behave correctly on every call while the campaign is still non-compliant, because the registrations are missing. You need both columns. Our compliance page sets out the first in detail, and the real estate page shows how it runs on property leads.

What to do next

Before the first campaign, confirm your principal entity registration, your telemarketer, your 140-series numbers and your A2P declaration with your operator. Then ask any calling vendor, in writing, which column of the table above it covers.

This article is general information, not legal advice.