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Fulfillment of regulatory requirements while sending bulk messages

TRAI has issued the Telecom Commercial Communications Customer Preference Regulations, 2018 (“TCCCPR, 2018”) on 19th July, 2018 to curb the menace of Unsolicited Commercial Communications (UCC). The regulations entirely came into force w.e.f. 28.02.2019. Since then, Telecom Service Providers (TSP),as per directions of TRAI, have communicated to the Principal Entities (PE) several times to complete the following activities for sending bulk communication:

a. Registration as Principal Entity (PE)
b. Assignment of header
C. Registration of Content Template
d.Transmission of PE id, header, Content id while offering for delivery of messages to TSPs
e. Registration of consent template (if any)
f. Acquisition of consumer consent (if any)

2. However, it is observed that you have still not fulfilled the regulatory requirements. As per the information provided by TSPs, based on scrubbing, some of your SMS traffic is not found to be incompliance to the regulatory requirements due to various reasons such as invalid template id, template not registered etc.

3. In this regard, apart from the analysis of the scrubbing data and other reports received from TSPs, a meeting was called with telemarketers, wherein, it was informed that you (PEs) are not passing the template ID and other mandatory fields as per regulatory requirements, while submitting the message for delivery through telemarketers, which results in rejection of messages.

4. As sufficient opportunity has been given to the Principal Entities to comply with the regulatory requirements, the consumers cannot be deprived of the benefits of the regulatory provisions. Accordingly, it has been decided that from 1st April 2021, any message failing in the scrubbing due to noncompliance of regulatory requirements will be rejected.

5. It is requested that you may fulfill the regulatory requirements before 31st March, 2021 to avoid any disruption in the communication with the customers from 1 April, 2021.

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