TRAI and DLT Rules for AI Calling in India: A 2026 Guide

If you are putting an AI voice agent on the phone in India, the rules that apply were not written for AI. They were written for telemarketing: TRAI’s Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR). TRAI has amended them three times since, most recently in February 2025 and on 18 September 2026. The 2026 amendment is the first to define A2P calls, a term that expressly includes artificial voice, and to treat undeclared A2P calls as spam.

This guide covers the rules as they stand on 25 September 2026, what they mean for AI calls, and where they are still unclear. Every point comes from TRAI’s published regulations and press releases, listed at the end.

TCCCPR 2018 and the DLT system

TRAI issued TCCCPR on 19 July 2018. A commercial call or SMS is legitimate only if the sender is registered, the person receiving it has not blocked that kind of communication (or has consented to it), and every step is recorded on a ledger all operators can check. The regulation required operators (TRAI calls them access providers) to adopt Distributed Ledger Technology, hence “DLT”. Since the 2025 amendment, commercial communication from an unregistered sender is treated as unsolicited commercial communication (UCC), TRAI’s term for spam.

Each operator runs its own DLT portal (Vodafone Idea’s is Vilpower, for example). Your business is the principal entity or sender. A telemarketer is a registered entity that delivers the calls or messages for you.

What you register on DLT

1. 1

   Your business (principal entity)

   Who you are, verified against business documents. Since 2025, registration also involves physical verification, biometric authentication and a linked mobile number.

2. 2

   Headers and calling numbers

   For SMS, the sender ID. For voice, the calling line identity (CLI): the number your calls show, from the 140 series or another series TRAI or DoT designates.

3. 3

   Content templates

   The fixed text of transactional and service messages, with variable parts marked. TRAI’s 2018 explanatory memorandum says transactional voice content should be registered as a template of the transcript.

4. 4

   Consent templates and consent records

   Explicit consent is recorded on the Consent Register: the customer sees the consent template, agrees and confirms by OTP. From the 2026 amendment, consent collected earlier through verifiable means can be registered later.

5. 5

   Your telemarketer chain

   Who delivers your traffic. Since 2025 the number of intermediaries is limited, so every call can be traced back to you.

Promotional, service and transactional calls

TCCCPR sorts commercial communication into categories, and the rules differ for each.

• Promotional: anything containing promotional material or advertising for a product or service. If promotional content is mixed into any other commercial call, the whole call counts as promotional.
• Transactional: sent to your customer in response to a transaction the customer started, within thirty minutes of it. Examples are OTPs, transaction alerts and confirmations. No explicit consent is needed.
• Service: sent to your customer about a product or service they already have (warranty, delivery, recalls, balance alerts and similar), and not promotional. Also covers calls that help complete an ongoing purchase after explicit consent. Under the 2026 text, that consent lasts up to seven days, and the customer can renew it for another seven days at a time.
• Government: sent on the directions of central or state government, or of TRAI. It cannot be blocked through preferences.

Rough examples: an AI call pitching a course to a new web lead is promotional; a fee-due reminder to an enrolled student is probably service; a call confirming an order placed minutes ago may be transactional. Confirm your own campaigns with your operator, and remember that one upsell line makes a service call promotional.

Number series: 140, 1600 and 1601

TRAI’s February 2025 amendment stops senders from using ordinary 10-digit numbers for telemarketing. Commercial calls come from designated series, so people can tell from the caller ID what kind of call it is.

The 2026 amendment also protects these series. Operators’ AI spam filters may not flag 140xx, 1600xx or 1601xx numbers as suspected spam, and call-management apps may not blanket-block or spam-tag them (a user can still block any number on their own phone).

DND preferences and consent

Customers set their preferences by calling or texting 1909, by USSD, through their operator’s app, or with TRAI’s DND app. They can block all promotional communication, or only some categories. The categories are banking, insurance, financial products and credit cards; real estate; education; health; consumer goods and automobiles; communication, broadcasting, entertainment and IT; tourism and leisure; and food and beverages.

Customers can also block by mode: voice calls, SMS, auto-dialler calls with a pre-recorded announcement, auto-dialler calls connected to a live agent, and robo-calls. They can block by time band and by day type too.

• Explicit consent recorded in the Consent Register lets a promotional call through even when the customer has blocked that category.
• Enquiries count for seven days. Once the 2026 amendment takes effect, a customer’s enquiry supports commercial communication for only seven days from the enquiry. The enquiry must be in writing or digital, and you must keep it in a verifiable form. The 2018 text allowed three months for an enquiry.
• Opt-outs stick. Since 2025, you may not ask someone who opted out for consent again for 90 days. Promotional messages must carry an opt-out option.
• Complaints are easier. Customers can complain within seven days (it used to be three). They can complain about unregistered senders without registering any preference first. They can also report suspected spam or fraud on the Department of Telecommunications’ Sanchar Saathi portal, through its Chakshu facility.
• Data protection still applies. The 2026 amendment says TCCCPR consent does not exempt a sender from its obligations under the Digital Personal Data Protection Act, 2023.

Is there a rule on calling hours?

We found no single “calling hours” clause for all commercial calls. What TCCCPR has is time-band preferences. Of the nine bands in its schedule, four are off by default for every customer unless the customer switches them on: 00:00–06:00, 06:00–08:00, 08:00–10:00 and 21:00–24:00. Read plainly, promotional communication is expected between 10:00 and 21:00 unless a customer has opted in to other bands. The 2026 amendment confirms that service and transactional communication is not blocked by time band.

Sector rules can add limits. For example, RBI’s rules on recovery agents (first issued in a 2022 circular, now part of its Responsible Business Conduct Directions) tell lenders to make sure they and their agents do not call borrowers before 8:00 a.m. or after 7:00 p.m. to recover overdue loans. If your AI agent makes collection calls for a lender, that window applies.

What happens if a sender breaks the rules

• Complaint-based action (2025): if you are unregistered, or make promotional calls from service or transactional numbers, then with complaints from five or more people within ten days, and an investigation that finds spam, all your outgoing services (PRI and SIP trunks included) are barred by every operator for 15 days. On a repeat, all your telecom resources are disconnected for a year and you are blacklisted.
• AI-flag-based action (2026): if operators’ AI/ML systems flag five or more of your numbers within ten days, you face KYC re-verification, then physical verification and a 15-day barring if misuse is found, then the one-year disconnection. Three complaints plus an AI flag will also trigger action (from 90 days after publication).
• Security deposits: operators may take one from senders and telemarketers and forfeit it for violations.
• Money penalties mostly fall on operators (for example ₹2 lakh, then ₹5 lakh, then ₹10 lakh per instance for misreporting spam counts). For a business, the real cost is losing its phone lines.

What changed in 2025 and 2026

The 2026 amendment was notified on 18 September 2026. Most of it comes into force 30 days after publication in the Official Gazette, the A2P declaration and A2P charge after 60 days, and the appeal mechanism and AI-corroborated complaint threshold after 90 days. None of it is in force as we write, but plan for it now.

What this means for AI voice calls

Your AI agent is an A2P caller. The 2026 definition covers calls “initiated by an application, software system, or automated platform without direct human dialling”, including “pre-recorded/artificial voice technologies”. Back in 2018, TCCCPR already defined robo-calls as calls “using an artificial or prerecorded voice to interactively deliver a voice message without the involvement of human being on calling side”. A conversational AI agent fits both definitions as we read them.

TRAI considered carving AI out, and decided not to. During consultation, stakeholders asked for AI-enabled calls, agent-assisted calls and calls handed from an AI or IVR to a human to be excluded from A2P declaration. TRAI kept the definition. It explained that the network cannot tell a human voice from “a pre-recorded or artificially generated human voice”, so bulk callers must declare A2P calling themselves.

People can block robo-calls specifically through the “robo-calls” mode. Ask your operator how AI calls are scrubbed against it.

Your calling pattern matters. The 2025 amendment tells operators to watch for unusually high call volumes, short call durations and low incoming-to-outgoing ratios. A campaign with thousands of very short calls can look like spam even when the content is fine.

These points are still unclear for AI calls. Raise each one with your operator:

• Content templates for live speech. An AI agent composes what it says during the call. We found no published way to register that. Ask your operator what they expect.
• Mixed calls. A service call that drifts into an offer becomes promotional. Keep the agent in its category.
• Service calls in other sectors. Which series to use is not settled in anything we found.
• Telling the caller it is an AI. TCCCPR’s disclosure is to the operator. We found no TCCCPR rule that the call must announce an AI. Many teams disclose anyway, and sector rules may differ.
• Live transfer to a human. TRAI declined to exclude AI calls that hand over to a human, so treat them as A2P.

A pre-launch checklist

1. 1

   Confirm your DLT registration

   Register as a principal entity and find out which registered telemarketer delivers your calls.

2. 2

   Get the right numbers

   140 series for promotional campaigns; for service calls, the series your operator confirms for your sector.

3. 3

   Declare A2P calling

   Tell your originating operator that you run automated calls, and from which number ranges. Don’t wait for the 60-day date.

4. 4

   Classify each campaign

   Promotional or service? Keep offers out of service scripts.

5. 5

   Keep consent and enquiry evidence

   Save the form, timestamp, source and the text the person agreed to. Call enquiries within seven days.

6. 6

   Honour opt-outs on the call

   When someone says “don’t call me”, stop calling them, record it, and don’t ask again for 90 days.

7. 7

   Set calling windows

   Promotional calls between 10:00 and 21:00, plus any sector rules, such as RBI’s 8:00 a.m. to 7:00 p.m. window for recovery calls.

8. 8

   Watch your patterns

   Track complaints, very short calls and daily volumes before your operator does.