India’s telecom regulator is putting a price on automated bulk calls for the first time. If your business runs outbound diallers, this affects your operating costs directly — and compliance is now the cheapest option.
Where this stands today: TRAI’s draft Third Amendment closed for public comments on April 12. Counter-comments due April 27. Implementation expected mid-2026. You have roughly 60–90 days to get your outbound calling stack compliant.
Indian businesses have been running automated outbound calls — OTP deliveries, EMI reminders, admissions follow-ups, delivery updates — through cheap, unregulated person-to-person infrastructure for years. TRAI is closing that gap.
The proposal: a termination charge of up to 5 paise per minute on all Application-to-Person (A2P) calls — automated calls made by software to customers. Small per call. Not small at scale.
What it costs at real call volumes
₹50,000 new monthly cost — per 10 lakh automated calls.
At 5 paise/minute on 1-minute calls. A BFSI collections team running 30–50 lakh calls/month faces ₹1.5–2.5 lakh in new costs. Every month. Without any change to their operations.
There is also a new administrative hook: businesses must declare A2P usage to their operator in advance. Calls made without prior declaration get classified as unsolicited commercial communication — which means potential blocking, not just a fine.
The exemption that changes everything
This is the most important detail in TRAI’s proposal — and most businesses will miss it.
Charge applies — non-compliant calling:
- Standard mobile or landline numbers for automated calls
- Undeclared automated calls to customers
- Unregistered outbound infrastructure
- Any call outside the 140 or 1600 series
Fully exempt — compliant registered series:
- Registered 140 series (promotional outbound)
- Registered 1600 series (BFSI transactional calls)
- Government and constitutional body calls
- TRAI-authorised agency communications
Businesses already on registered 1600 or 140 series with a compliant platform pay nothing extra. The charge is targeted squarely at unregistered, non-compliant infrastructure. Compliance is now a cost saving, not just a legal requirement.
Who needs to act right now
If your team runs automated or dialler-based outbound calling in any of these verticals, your cost exposure under this regulation is immediate — the moment it is notified:
- 🏦 BFSI — collections teams, EMI reminders, KYC follow-ups
- 🎓 EdTech — admissions diallers, fee collection, demo reminders
- 🛒 E-commerce — delivery OTPs, order status, return coordination
- 🏥 Healthcare — appointment alerts, prescription follow-ups
- 📦 Logistics — fleet coordination, delivery confirmation calls
3 things to do before it lands
01 — Audit every automated outbound flow Which calls go through diallers? What number series are they using? Has your operator been notified? Any call outside 140 or 1600 series is exposed to the new charge.
02 — Confirm your platform supports 1600-series natively If you are in BFSI and still routing transactional calls through standard mobile numbers — or through a platform without DoT-licensed 1600-series support — fix this before enforcement hits. This is not a feature to evaluate later. It is a compliance requirement now.
03 — Pre-declare A2P usage to your access provider The amendment requires this in advance. Undeclared automated calls become UCC — blocked outright. That is worse than a 5-paise charge.
Bottom line
TRAI’s 5-paise rule is not a threat to compliant businesses. It is a cost that lands on everyone still using cheap, unregistered infrastructure for automated calling.
The exemption for registered 1600 and 140 series means being compliant is now literally cheaper than not being compliant.
Platforms like Smartflo by Tata Tele Business Services run on DoT-licensed, carrier-grade infrastructure with native 1600-series support for BFSI transactional calling and DLT-registered 140-series for outbound campaigns. Businesses on Smartflo are already exempt. Businesses not yet on compliant infrastructure have a closing window to migrate.
Evaluating compliant cloud telephony options?
Download the free Cloud Telephony Buyer’s Checklist — it covers 1600-series support, DLT registration, DoT licensing, and the exact questions to ask any vendor before the new charge hits.
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