CRM Costs, Price Drivers and 2026 Rules
TRAI rules for CRM SMS and calls in 2026: DLT registration, headers, templates, 140 and 1600/1601 series
What a small business sending SMS or making sales calls from a CRM must do under TRAI's TCCCPR 2018 and the 2025 and 2026 amendments — DLT, headers, consent, number series.
If your CRM sends commercial SMS or makes sales calls over Indian telecom networks, you must work within TRAI's Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR). In practice that means: register your business as a principal entity on a telecom operator's DLT (distributed ledger) platform, register your SMS headers and content templates, send promotional messages only to people who have not blocked them, make promotional calls only from 140-series numbers, and — under the Third Amendment Regulations of 18 September 2026, once that provision takes effect 60 days after Gazette publication — declare automated (A2P) calls to your operator in advance. Service and transactional calls are moving to designated series: 1600 for regulated financial entities and government, 1601 for other sectors in phases. This guide explains the rules as a CRM buyer needs them; it is part of the CRM costs and rules overview. It is general information, not legal advice.
Who the rules apply to
The TCCCPR regulate commercial communication — messages and calls about goods or services — sent by senders (your business, a "principal entity") through telemarketers (SMS aggregators, calling platforms) and access providers (telecom operators). Operators enforce the rules: they register senders, scrub messages against customer preferences, and suspend or disconnect resources after complaints.
Your CRM vendor or SMS provider is usually your telemarketer or works with one. They cannot register your business for you without your documents, and you remain the sender responsible for headers, templates and consent.
The DLT registrations you need
| Registration | What it is | Who does it |
|---|---|---|
| Principal entity | Your business, verified with KYC documents | You, on an operator's DLT portal (once; visible across operators) |
| Header | The sender ID shown on SMS (letters for most commercial traffic) | You, linked to your entity |
| Content template | The approved text of each SMS, with variable fields | You, before sending |
| Consent template | The wording used to seek consent for promotional messages | You, where you rely on explicit consent |
| Telemarketer chain | The aggregators who deliver your traffic | You and your provider |
An SMS that does not match a registered header and template is generally blocked. Build template registration into campaign planning; it is the most common reason a CRM SMS launch is delayed.
The February 2025 amendment
The Telecom Commercial Communications Customer Preference (Second Amendment) Regulations, 2025, notified by TRAI on 12 February 2025, came into force in stages (30 and 60 days after Gazette publication). Points that matter for CRM users:
- Header suffixes. Operators suffix SMS headers with -P (promotional), -S (service), -T (transactional) or -G (government), so recipients can see the type of message.
- Number series for calls. Promotional voice calls are to come from 140-series numbers, and the use of ordinary 10-digit numbers for telemarketing was curbed.
- Opt-out. Promotional messages must carry an opt-out mechanism.
- Consent for ongoing transactions. Explicit consent obtained to facilitate an ongoing transaction is valid for seven days, unless TRAI specifies otherwise.
- Complaints. Customers can complain within seven days of receiving unsolicited communication (previously three), and action against unregistered senders is triggered at five complaints within ten days (previously ten within seven).
- Penalties on operators that fail to curb unsolicited communication rise from ₹2 lakh for a first violation to ₹10 lakh for repeated violations — which is why operators enforce strictly against senders.
The September 2026 amendment
The Telecom Commercial Communications Customer Preference (Third Amendment) Regulations, 2026 (05 of 2026) are dated 18 September 2026. Under the commencement clause (regulation 1(3)), most provisions take effect 30 days after publication in the Gazette; regulations 4 (A2P call declaration), 6 (interface for virtual network operators), 8(a) (header and template misuse) and 18 (A2P termination charge between operators) after 60 days; and the amendments listed in the Annexure (including the new appeal route) after 90 days. We could not confirm the Gazette publication date, so we give no calendar dates: because the notification is dated 18 September 2026, the 60-day provisions cannot apply before mid-November 2026 and the 90-day ones before mid-December 2026. Check the exact dates on TRAI's website and the e-Gazette. Changes relevant to CRM users:
- A2P calls must be declared. An "Application-to-Person" call — one initiated by software such as an auto-dialler, robocall or pre-recorded or artificial voice — must be declared to your originating operator in advance, with the number ranges (CLIs) you will use, and recorded on DLT. Undeclared A2P calls are treated as unsolicited commercial communication. If your CRM's dialler places calls automatically, this applies to you (one of the provisions taking effect after 60 days).
- Consent definitions. Explicit consent is consent verified and recorded by a consent registrar, or obtained by you through verifiable means and then registered in the Consent Register as TRAI specifies. An explanation states that the TCCCPR do not exempt senders from the Digital Personal Data Protection Act, 2023.
- Relationship-based communication is tied to an enquiry made by the recipient within the previous seven days, or an application for products or services within the previous three months, with the enquiry kept in verifiable form.
- Service messages (order and delivery updates, warranty, OTPs and similar) do not require explicit consent, provided they are not promotional.
- Header and template misuse. If your header or template is misused — for example through leaked CRM or SMS API credentials — operators suspend it quickly, and (once this 60-day provision applies) you must reset passwords and API keys within three business days, file a complaint with law enforcement and review all headers and templates. Treat your SMS API keys in the CRM like bank passwords.
- Spam flagging. Calls from the 140, 1600 and 1601 series are not to be flagged as suspected spam by operators' detection systems, while 10-digit numbers showing spam-like patterns can be flagged and their senders' resources barred.
Which number series for which call
| Call type | Number series | Status in October 2026 |
|---|---|---|
| Promotional calls (offers, sales pitches), any sector | 140xx | Mandatory; customers who block promotional categories do not receive them |
| Service and transactional calls by RBI, SEBI, IRDAI or PFRDA-regulated entities, and government-to-citizen calls | 1600xx | Designated under TRAI and DoT directions |
| Service and transactional calls by other sectors | 1601xx | Being operationalised in phases under a TRAI direction of 10 August 2026, starting with utilities, logistics and courier companies |
| Ordinary 10-digit numbers | — | Not for telemarketing; still used for many service calls, but watch for spam-flagging |
Costs to budget
| Item | Illustrative cost |
|---|---|
| DLT entity registration | One-time fee charged by the operator, plus renewal on some platforms (check the portal) |
| Header and template registration | Usually no or low fee; staff time for drafting and approval |
| 140-series number for promotional calls | Monthly rental and per-minute charges from your operator or provider |
| SMS | Per message, plus any DLT scrubbing charges added by the aggregator |
| Compliance time | 4–8 hours a month for templates, consents and complaint checks |
Ask your provider to show these as separate lines in the quote; then add them to the fixed costs in the TCO estimator.
What to require from a CRM or provider
- Support for registered header and template IDs on every SMS, and rejection of unregistered content before sending.
- Storage of consent records (source, date, purpose) per contact, and immediate suppression after opt-out.
- A dialler that can use 140-series numbers for campaigns and supports the A2P declaration.
- Two-factor login and restricted API keys, because misuse of your header is now your problem to fix.
- Reports of blocked messages and complaints, so you can fix problems before your resources are suspended.
The DND and spam complaints guide covers what happens when customers complain, and the real estate telecalling example shows the rules in a costed workflow.
FAQ
Do transactional SMS like OTPs need DLT registration?
Yes. All commercial SMS, including service and transactional ones, need a registered header and template; only the consent and preference rules differ by category.
Can my salespeople call leads from their own mobile numbers?
Personal follow-up on a lead's own enquiry is common, but bulk or automated promotional calling from 10-digit numbers is not permitted and invites complaints and disconnection. Use 140-series numbers for promotional calling and keep enquiry records.
Does TRAI regulate WhatsApp messages?
The TCCCPR cover communications over telecom networks (SMS and voice). WhatsApp is governed by Meta's business policies, but the DPDP Act and consumer protection law still apply.
Sources
- Telecom Regulatory Authority of India — TCCCPR 2018, Second Amendment 2025 (12 February 2025), Third Amendment 2026 (18 September 2026), directions on 1600 and 1601 series
- Department of Telecommunications — National Numbering Plan and number series allocation
- e-Gazette of India — Gazette publication dates of the regulations
- Ministry of Electronics and Information Technology — DPDP Act, 2023
