TRAI new rules 2026: what changes for AI and automated calls

Why TRAI brought automated calls under its spam rules

The Telecom Regulatory Authority of India (TRAI) regulates business calls and messages through the Telecom Commercial Communications Customer Preference Regulations (TCCCPR), 2018. Those rules decide who may send promotional calls and texts, how customers opt out through Do Not Disturb (DND), and how operators deal with spam. Until 2026 they were written mostly around what a call said, not how it was dialled.

Operators' own figures pushed TRAI to look at the dialling. In April 2026, operators disconnected 20,591 connections for spam violations. Of those, 15,736 were SIP or PRI lines, the business trunk connections used for A2P calling, a share TRAI put at about 75% (TRAI Third Amendment, explanatory memorandum). Software can place thousands of calls an hour, which is what makes it useful to legitimate businesses and attractive to spammers.

TRAI published a draft Third Amendment for consultation on 13 March 2026, took comments until 19 April and counter-comments until 4 May, and held an open house discussion on 3 June. It notified the final text on 18 September 2026 (TRAI Press Release 119/2026). The amendment builds on the Second Amendment of 12 February 2025, which created the 140 and 1600 number series and already asked senders to disclose their use of autodiallers and robocalls.

Two older terms run through the rules. UCC (unsolicited commercial communication) is TRAI's word for spam. DLT (distributed ledger technology) is the shared registry where operators record senders, their numbers, their message templates and their customers' consents.

Is AI calling legal in India?

Yes. Nothing in the amendment bans AI voice agents, IVR (interactive voice response) campaigns or autodiallers. Cold calling with AI is not banned either: a promotional call is lawful if the customer consented or has not blocked that category through DND, and if it comes from a 140-series number. What the amendment adds is a label, A2P, and a set of duties that follow from it.

TRAI defines an A2P call as a voice call "initiated by an application, software system, or automated platform without direct human dialling" (new regulation 2(ea), TCCCPR Third Amendment). The definition names autodialling, robocalls and pre-recorded or artificial voices. An AI voice agent that places outbound calls fits it squarely.

The test is how a call is dialled, not what it says. TRAI explained that its definition of a commercial communication turns on content, while the A2P definition turns on the technical way a call is generated. A bank's balance alert dialled by software is therefore an A2P call, even though it is a service message rather than a sales pitch.

Declaring A2P calls and choosing a number series

The declaration is the change most likely to catch businesses out, because it reaches every number that software dials from. A sender tells its originating operator, the one whose network the calls start on, in advance that it makes A2P calls. It also lists the CLI (calling line identification) ranges it will use, meaning the caller numbers people see on their screens (substituted regulation 4).

The operator records the declaration on the DLT platform, together with the number series assigned to the sender. Holding 140, 1600 or 1601 numbers does not excuse a sender from declaring them. From 27 November 2026, a call made without a declaration is treated as UCC, which exposes the numbers behind it to complaints, barring and disconnection however legitimate the call was.

Consent after an enquiry, and older consents

Declaring numbers tells the network who is calling. Consent rules still decide whom you may call, and the amendment's sharpest change here concerns calls that follow a customer's enquiry. From 28 October 2026, a business may call on the strength of an enquiry for only seven days after it. The enquiry must have been made in writing or digitally, and kept in a verifiable form.

Before the amendment, an enquiry or an application created a relationship for three months, and the enquiry did not need to be written down. Applications keep the longer window, so a customer who applied for a loan or a policy can still be called about it for three months. TRAI said the enquiry route exists mainly for e-commerce and e-service platforms, and that the written record is there to stop it being used as cover for spam.

Older consents collected outside the operators' consent system also get a route back in. From 28 October 2026 they count if you obtained them through verifiable means and then register them in the Consent Register (new definition 2(y)). Before, only consents verified directly with the customer and recorded by the operators' Consent Registrar counted.

How spam flags and complaints lead to action

From 28 October 2026, mistakes over consent or declarations reach consequences faster, because operators' spam detection is written into the rules. Operators use AI and machine-learning systems to flag caller numbers likely to be spam (new regulation 21A). The operator receiving the calls must share flagged numbers with the sender's operator within two hours, and the sender is told by SMS, email or both. A TRAI Direction of 27 February 2026 first required this, and the amendment moves it into the regulations.

If five or more of one sender's numbers are flagged within 10 days, operators act in steps. The first time, the sender's KYC (know-your-customer) details are re-verified within three business days. The second time, a physical check follows within five business days. If that fails or misuse is found, outgoing calls are barred for 15 days on all operators, and repeat cases can end in a one-year disconnection and blacklisting.

A wrong flag can be challenged. The operator must remove it if the sender's justification holds, so consent records and the A2P declaration are worth keeping where they can be produced quickly.

Complaints from the public run alongside the flags. For unregistered telemarketers, meaning senders not registered with an operator for commercial calls, five complaints from different people in 10 days still trigger action on their own. From 27 December 2026, three are enough if any of the sender's numbers is also AI-flagged. Either way, the operator must suspend the numbers at once and investigate (regulation 25(5)). From the same date, customers unhappy with how a complaint was resolved can appeal within 15 days to the operator's Appellate Authority, through the DND app, the operator's app or 1909.

The A2P termination charge, and who pays it

The last major change puts a price on A2P calls made outside the designated series. The A2P termination charge is up to ₹0.05 (five paise) per minute, counted in one-minute pulses (new regulation 35A). The operator delivering the call may bill the operator that sent it, but never more than its own lowest tariff to the senders or telemarketers it serves.

There is no charge on A2P calls from the 140, 1600 and 1601 series, or on calls made by or for TRAI. TRAI describes the charge as a deterrent rather than cost recovery, modelled on the existing five-paise charge on commercial SMS, and it is the first such charge on A2P voice calls. Its effect is to make the designated series the cheaper route as well as the protected one.

Businesses are not billed the charge directly. Whether any of it reaches you depends on your contract with your operator, which is worth asking about before 27 November 2026.

Getting automated calling ready for 27 November 2026

The declaration can only be as complete as a business's list of what dials for it. That list usually runs longer than expected. It covers AI voice agents, IVR blasts and predictive diallers, plus any vendor or platform that places calls on the business's behalf, each with its own numbers and operator.

From there the work follows the order of the rules. Each campaign is matched to a number series by purpose, each operator receives a declaration covering every caller number range, and the operator confirms the entry on DLT. Consent records, written enquiries and daily flag and complaint counts then keep the numbers in good standing once calling starts. The calling rules by country tool summarises the India rules alongside other markets.

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