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Auto-Dialers and Robocalls on the 140 Series: What the New TRAI Rules Say in 2026

140 series auto dialer

AI Summary: India’s Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR), as amended on 12 February 2025, now require every 140 series auto dialer or robocall sender to notify their Originating Access Provider in advance and in writing about the use and intended objective of such technology. Promotional auto-dialer and robocall traffic must route exclusively through the 140 series; service and transactional robocalls must use the 160 series. Entities that fail to comply face financial disincentives of up to Rs 10 lakh per violation. They also face usage caps and blacklisting across all telecom resources for up to one year. FreJun’s DLT-integrated platform helps BFSI entities and enterprises manage the pre-declaration workflow, template registration, and compliant call routing for both 140 and 160 series numbers.

Key Facts at a Glance

ItemDetail
RegulationTCCCPR, 2018 (Second Amendment, 12 Feb 2025)
Governing bodyTRAI / DoT
Applies toAll registered senders and telemarketers using auto-dialers or robocalls
Number series for promotional robocalls140xxxxxxx (mandatory)
Number series for service / transactional robocalls160xxxxxxx / 1601xxxxxxx (mandatory)
New obligation (Feb 2025)Advance written notification to Originating Access Provider before using auto-dialer or robocall
First-violation penaltyRs 2,00,000
Blacklist trigger5 valid complaints in any rolling 10-day period
Maximum blacklist durationUp to 1 year across all telecom resources and all TSPs

  • The TCCCPR Second Amendment (12 Feb 2025) makes advance written notification to the Originating Access Provider (OAP) mandatory before any sender uses auto-dialers or robocalls for commercial communication.
  • Promotional auto-dialer and robocall traffic must use the 140 series only; service and transactional robocalls must route through the 160 series or 1601 series for BFSI entities.
  • Mixing promotional content with service or transactional content in a single robocall classifies the entire call as promotional, triggering the full promotional compliance stack.
  • Penalties run from Rs 2 lakh (first violation) to Rs 10 lakh per instance (third and subsequent violations), with disconnection of all telecom resources for up to one year on repeat breaches.
  • FreJun’s platform handles pre-declaration documentation, DLT template registration, and routing segregation so compliance teams can focus on substantive obligations rather than technical setup.

Quick Answer: Under the TCCCPR Second Amendment (12 Feb 2025), every 140 series auto dialer and robocall sender in India must notify their Originating Access Provider in advance and in writing before deployment. Promotional robocalls use the 140 series exclusively; service and transactional robocalls must use the 160 series. Non-compliance attracts penalties up to Rs 10 lakh per instance and possible blacklisting.

In This Article

  1. What Are 140 Series Auto Dialer and Robocall Rules Under TRAI?
  2. What Is the New 2025 Obligation Every Sender Must Know?
  3. 140 Series vs 160 Series for Robocalls: Which Number Must You Use?
  4. What Happens When Promotional Content Mixes With Service Content?
  5. What Consent Rules Apply to Auto-Dialer and Robocall Campaigns?
  6. How Does DLT Template Registration Work for Robocall Scripts?
  7. What Are the Penalties for Non-Compliant 140 Series Auto Dialer Use?
  8. How FreJun Helps Entities Stay Compliant
  9. Frequently Asked Questions
  10. Key Takeaways
  11. Compliance Disclaimer
  12. References and Sources

India’s 140 series auto dialer and robocall compliance rules changed fundamentally on 12 February 2025. The TCCCPR, as amended that day, now places explicit obligations on every sender. These obligations cover anyone using automated dialing or pre-recorded voice technology. Industry reports indicate roughly 147 million spam-call complaints in 2024 alone, a figure that pushed TRAI to act. Banks, NBFCs, insurance companies, fintechs, BPOs, and recovery agencies that run outbound calling campaigns must understand these rules before their next automated campaign launches.

In my practice advising telecom-sector clients, this amendment generates more day-to-day questions than almost any other change TRAI has made. The reason is its direct impact on core calling workflows. The reason is simple: auto-dialer technology is deeply embedded in collections, OTP delivery, EMI reminders, and insurance renewals. Suddenly, each of those workflows carries a new pre-condition. This article covers every rule: the correct number series, the consent framework, DLT registration steps, and penalties for non-compliance.

What Are 140 Series Auto Dialer and Robocall Rules Under TRAI?

Definition — Auto-Dialer: An auto-dialer is software or hardware that automatically dials numbers from a pre-loaded list. It connects answered calls to a live agent or a pre-recorded message. Under TCCCPR, any technology that initiates calls without a human manually dialling each number qualifies as an auto-dialer.

Definition — Robocall: A robocall is a voice call that delivers an artificial or pre-recorded message to the recipient. There is no live human on the calling side at the time of delivery. Indeed, AI-generated voice messages fall within this definition under the 2025 regulatory framework.

Moreover, auto-dialers and robocalls represent the two primary mechanisms by which entities scale outbound calling. TRAI has long regulated commercial communication more broadly, but the 2025 amendment specifically targets these technologies. Before February 2025, the TCCCPR did not require any advance notification to the network before deploying auto-dialer or robocall technology. That gap is now closed.

Why Did TRAI Specifically Target Automated Calling in 2025?

TRAI’s Explanatory Memorandum to the 2025 amendment states the regulatory rationale plainly. Entities have increasingly turned to auto-dialers and robocalls for commercial communications, causing widespread consumer nuisance. The EM further acknowledges that certain legitimate services depend on robocalls for time-sensitive notifications such as emergency alerts, transaction updates, and real-time service changes. As a result, TRAI chose a disclosure-first approach rather than an outright ban. All senders must pre-declare their use so the network can enforce consumer-blocking preferences.

Additionally, the rapid rise of AI-based voice tools has made robocalls cheaper, multi-lingual, and available around the clock. TRAI and the S.S. Rana analysis of March 2026 confirm that TRAI is already considering further amendments specifically addressing AI-generated voice disclosures and consent-verification systems for AI calls. The 2025 obligation is therefore the first regulatory layer in what will likely be a progressively tighter framework for automated outbound calling in India.

What this means for your compliance team: any investment in auto-dialer or AI-voice technology must build on the 2025 compliance architecture. The pre-amendment baseline no longer applies. Setting up the notification obligation correctly now avoids a costly retrofit later.

Get Legal Guidance

The auto-dialer pre-declaration requirement is new and many entities are still catching up. FreJun’s legal and compliance team can walk you through the exact notification format, timing, and documentation your Originating Access Provider expects.

What Is the New 2025 Obligation Every Sender Must Know?

Specifically, the core obligation for any 140 series auto dialer operator introduced by the TCCCPR Second Amendment (12 February 2025) sits in the substituted Regulation 4. The text states: every sender shall notify the Originating Access Provider in advance about the use of auto-dialers or robocalls. The notification must also state the intended objective of such calls, and it must be in writing. Entities must file this before deployment, not after the factly.

What Must the Advance Written Notification Contain?

The regulation specifies two elements: the use of auto-dialer or robocall technology, and the intended objective of such calls. In practice, a compliant notification should cover the following points at minimum.

  • Identity of the sender as registered on the DLT platform, including the Header ID.
  • Technology description: whether the system is an auto-dialer, a pre-recorded robocall, an AI-voice system, or a combination.
  • Intended objective: the category of communication (promotional, service, or transactional) and the specific use case, for example EMI reminders, OTP delivery, or policy renewal alerts.
  • Number series from which calls will originate: 140 series for promotional calls, 160 series for service or transactional calls.
  • Estimated call volume per day or per campaign cycle.

Furthermore, the sender must direct this notification to the Originating Access Provider (OAP). The OAP is the telecom service provider whose network the sender uses for outbound calls. This is typically your SIP trunk or PRI provider, not TRAI directly. Sending the notification to TRAI or to a different TSP does not meet the obligation.

Why the Notification Enables Consumer-Level Blocking

Specifically, the regulatory purpose behind the notification is network-level enforcement of consumer preferences. Once the OAP knows that a specific sender uses automated calling for promotional purposes on the 140 series, it applies DND preferences at the network layer. This blocks delivery to subscribers who have opted out of promotional calls. Without this notification, the network cannot tell a compliant promotional robocall from a fraudulent one. as a result, the notification is not merely administrative paperwork; it is the technical handshake that enables the broader spam-control infrastructure to function correctly.

What this means for your compliance team: file the notification before the first call is sent. Filing at the time of a complaint or audit is too late. Most OAPs now maintain a standard notification form or portal entry for this purpose. Verify your OAP’s specific process, since TRAI has not prescribed a universal template.

140 Series vs 160 Series for Robocalls: Which Number Must You Use?

The answer depends entirely on the purpose of the call. TRAI has drawn a hard line between the two series. The 2025 amendment reinforces that boundary specifically for automated calling technology.

Call TypeNumber SeriesBFSI Sub-PrefixKey Condition
Promotional robocall (marketing, offers, campaigns)140xxxxxxxNot applicableSender must be a registered telemarketer; DND preferences enforced
Service robocall (e.g. policy renewal alert, flight delay)160xxxxxxx1601xxxxxxx for RBI/SEBI/PFRDA/IRDAI entitiesCall must relate to an existing contract or service the recipient has used
Transactional robocall (OTP, account alert, fraud warning)160xxxxxxx1601xxxxxxx for BFSIMust be triggered within 30 minutes of a customer-initiated event
140 series auto dialer

140 Series Auto Dialer Rules for Promotional Robocalls

Specifically, the DoT allocated the 140 series for promotional and telemarketing voice calls. This is confirmed by the DoT Press Release dated 30 May 2024 (PRID 2022249). For robocall campaigns on this series, the following rules apply together.

  • Registered telemarketer status: The sender must register as a telemarketer on the DLT platform before placing any promotional call, automated or otherwise.
  • Explicit consent requirement: Promotional robocalls require prior explicit consent from each recipient. Inferred or implied consent does not suffice for promotional communication. Notably, the 2025 amendment further tightened this rule: explicit consent now lasts only 7 days from the date of grant for the specific stated purpose.
  • DND compliance: Full DND-registry filtering applies to the 140 series number. The network blocks calls to subscribers who have registered a preference against promotional calls.
  • Advance OAP notification: As discussed, written notification to the OAP is mandatory before the first automated promotional call is placed.
  • Template registration: Every sender must register each pre-recorded script as a content template on the DLT platform and must carry a valid Template ID passed in call signalling.
  • Call hours: Although TCCCPR does not specify calling hours for transactional calls, promotional calls conventionally follow the 10:00 to 19:00 IST window as the industry standard enforced by most OAPs.

What this means for your compliance team: a promotional robocall campaign on the 140 series carries a significantly higher compliance burden. Each element above must be satisfied before the first automated call goes out. Each element above must be satisfied before the first automated call goes out.

Rules Specific to the 160 Series for Service and Transactional Robocalls

Service and transactional robocalls must originate from the 160 series. For BFSI entities regulated by RBI, SEBI, PFRDA, or IRDAI, the mandatory sub-prefix is 1601xxxxxxx. This is confirmed by the DoT Press Release (PRID 2022249, 30 May 2024). TRAI’s Direction of 19 November 2025 (PRID 2191647) set phase-wise adoption deadlines. Mutual Funds and AMCs must comply by 15 February 2026. Qualified Stockbrokers must comply by 15 March 2026.

Additionally, the transactional robocall window is strict. A transactional call, whether agent-dialled or automated, may only be placed within 30 minutes of the customer-initiated event. An OTP delivered 45 minutes after login falls outside the transactional category. So does an EMI alert sent outside the transaction window. Both must meet service-call consent requirements instead. In practice, this 30-minute window means OTP auto-dialer systems must integrate tightly with core banking or payment platforms. The trigger-to-call latency must stay within the permitted window.

What this means for your compliance team: the robocall system architecture must reflect call-type segregation at the routing layer. A written policy alone does not satisfy auditors. The same dialler instance cannot route 140 promotional traffic and 1601 transactional traffic through the same number pool. TRAI auditors and sectoral regulators have been clear that a written policy without enforced routing logic does not constitute adequate compliance.

What Happens When Promotional Content Mixes With Service Content?

This is one of the most practically significant rules from the 2025 amendment. It directly affects call-centre scripts that blend service information with renewal or upsell offers. Specifically, the amendment clarifies that if promotional content is mixed with any other type of communication, TRAI classifies the entire communication as promotional. There is no partial classification.

Practical Examples of the Mixed-Content Rule

For example, consider this scenario. Take this example: an insurance company uses a robocall to remind policyholders of an upcoming premium due date. It also appends a discount offer for upgrading to a higher-value policy before that date. Under the 2025 amendment, TRAI treats the entire call as promotional. It must therefore originate from the 140 series, not the 160 series. It requires prior explicit consent, full DND compliance, and a promotional template on the DLT platform.

Similarly, a collections robocall including an EMI reminder and a new loan product mention is promotional in its entirety. The EMI reminder alone would have been a compliant transactional communication on the 1601 series. Adding the product mention moves the entire call into the promotional stack.

What this means for your compliance team is that compliance teams must review every robocall script for any promotional element before deployment. Therefore, script-writing teams and compliance teams must work together on every call design, not just at launch. A single unapproved promotional sentence in a transactional script can reclassify thousands of calls. TCCCPR penalties then apply to every one of them.

Consent under the TCCCPR Second Amendment operates differently depending on whether the call is promotional, service, or transactional. The following framework applies specifically to automated calling.

Promotional robocalls require prior explicit consent. The 2025 amendment defines explicit consent as consent obtained directly from the user. It must be recorded in the Consent Registrar on the DLT platform. Three additional rules tighten this consent requirement further.

  • 7-day validity: Explicit consent granted for a specific promotional purpose is valid for only 7 days. After that window, consent lapses. The entity must obtain fresh consent before placing another automated promotional call.
  • 90-day opt-out lockout: Once a subscriber opts out, the entity cannot contact them for the same purpose for 90 days. This applies to all commercial communication, including automated calls.
  • No consent solicitation from opted-out subscribers: During the 90-day lockout period, the entity may not call, message, or use any other channel to solicit a new consent. Any such attempt is itself a violation.

Furthermore, the Digital Consent Acquisition (DCA) framework on the DLT platform governs how consent is captured. Auto-capture mechanisms in mobile applications and websites must integrate with the DCA framework to ensure consent records are valid and auditable.

Additionally, service robocalls rely on implicit or inferred consent arising from the contractual relationship between the entity and the customer. The 2025 amendment clarifies that inferred consent lasts only for the duration of the underlying contract. Once the contract ends, inferred consent automatically lapses. Transactional robocalls, by contrast, rely on the customer’s own action as the triggering event, making them less consent-dependent, provided the 30-minute window is respected.

Additionally, both service and transactional robocalls on the 160 series must disclose at the start of the call that the call is automated. TRAI’s 2025 amendment mandates disclosure of auto-dialer or robocall use to the call recipient. This is a consumer-facing obligation, not just the back-end notification to the OAP. Failing to include an automated-call disclosure in the opening IVR message is a standalone violation, separate from the OAP notification obligation.

What this means for your compliance team: every robocall script must open with a disclosure statement. It must identify the entity and confirm the call is automated. Many compliance teams overlook this customer-facing disclosure requirement while focusing on the OAP notification. Both are mandatory.

How Does DLT Template Registration Work for Robocall Scripts?

Specifically, every voice script used in a robocall must be pre-registered as a content template on the DLT platform. This covers the IVR opener, the pre-recorded message body, and any DTMF-response branches. The template carries a unique Template ID. Crucially, the dialler must include that Template ID in call signalling for every outbound automated call. Calling with an unregistered, outdated, or blacklisted template is a violation. This applies regardless of whether the originating 140 or 160 series number is itself a valid allocation.

Practical Steps for DLT Template Registration of Robocall Scripts

In my practice advising telecom-sector clients, the DLT template registration step takes the longest for first-time registrants, often two to three weeks. The reason is that DLT platforms review the script for content compliance before assigning a Template ID.

Entities that submit scripts containing any promotional element on a transactional header see their template rejected and must restart the review. The steps below reflect the process most OAPs currently operate.

  1. Obtain a registered Header ID on the DLT platform if not already registered. The Header ID identifies the sending entity and must match the 140 or 160 series number allocation.
  2. Draft the script with the mandatory automated-call disclosure at the opening, the entity name, and the purpose of the call. Ensure no promotional element appears in service or transactional scripts.
  3. Submit the script to the DLT platform under the correct content category (promotional, service, or transactional). Misclassifying the category causes rejection.
  4. Await approval and note the Template ID assigned. Keep a record of the Template ID mapped to the script version and the date of approval.
  5. Configure the auto-dialer or robocall platform to pass the Template ID in call signalling for every outbound call using that script.
  6. Update the template every time the script changes, even for minor edits. Using an outdated template after a script change is a violation.

Furthermore, the 2025 amendment introduces mandatory annual self-certification for registered senders and telemarketers. Each year, therefore, the entity must certify that its headers and templates remain accurate and have not been misused. Auto-dialer operators should build this certification into their annual compliance calendar.

What this means for your compliance team is that template management for robocall scripts is a living obligation, not a one-time setup. Finally, assign ownership of template version control to a specific team member. Implement a change-management process that routes every script edit through a fresh DLT submission before the updated robocall goes live.

Talk to FreJun’s Legal Team

DLT template registration for robocall scripts involves nuances most compliance teams discover only after a rejection. FreJun’s team has walked dozens of BFSI entities through the exact submission format and approval workflow. Book a call to get the process right the first time.

What Are the Penalties for Non-Compliant 140 Series Auto Dialer Use?

The TCCCPR Second Amendment (12 February 2025) introduced a graded financial-disincentive structure covering all violations, including non-compliant 140 series auto dialer and robocall use. The penalties cascade through multiple layers, and a single non-compliant automated campaign can trigger more than one layer at the same time.

Financial Penalties Under TCCCPR

Financial disincentives under the 2025 amendment are structured as follows.

  • First violation: Rs 2,00,000
  • Second violation: Rs 5,00,000
  • Third and subsequent violations: Rs 10,00,000 per instance

These disincentives are levied separately for registered and unregistered senders. Notably, a single automated campaign reaching 500 non-consenting subscribers could be treated as 500 separate violations under aggressive enforcement. In practice, TRAI aggregates by campaign and sender rather than by individual call.

Operational Consequences: Usage Caps and Disconnection

Furthermore, beyond the financial penalties, the operational consequences are significantly more disruptive for entities that depend on automated calling at scale.

  • First violation of the complaint threshold (5 valid complaints in any rolling 10-day period): TRAI bars outgoing services on all telecom resources of the sender for 15 days.
  • Subsequent violations: TSPs disconnect all telecom resources of the sender, including PRI lines and SIP trunks, across all access providers for up to one year, and TRAI blacklists the entity.
  • Usage cap for unregistered telemarketers: if an entity deploys auto-dialers without having registered as a sender, TRAI classifies the entity as an Unregistered Telemarketer (UTM). UTMs face a usage cap of a maximum of 20 outgoing voice calls per day per number for six months on the second violation, followed by full disconnection on the third.

For a BFSI entity, a one-year blacklist is operationally catastrophic: OTPs stop, customer service calls stop, and collections cease entirely. The financial penalty is recoverable; the operational damage from a blacklisting cycle is not. This imbalance is precisely why TRAI designed the blacklisting power as the most severe lever in the enforcement tools.

What this means for your compliance team is that the complaint threshold, not the penalty quantum, is the trigger to watch most carefully. Five complaints in ten days sounds manageable until one realises that TRAI’s complaint system allows consumers to file without prior DND registration following the 2025 amendment. The practical exposure is therefore higher than the threshold number suggests.

140 series auto dialer

How FreJun Helps Entities Stay Compliant With the 2025 Auto-Dialer Rules

Overall, FreJun’s platform is purpose-built for the compliance architecture that the 2025 TCCCPR amendment demands. Rather than bolt compliance onto an existing generic dialler, FreJun integrates the regulatory obligations for 140 series auto dialer campaigns directly into the calling workflow. In practice, the compliance layer FreJun provides covers three areas relevant to the auto-dialer and robocall rules discussed in this article.

Routing Segregation, DLT Integration, and OAP Documentation

First, FreJun manages routing segregation at the system level, enforcing the technical separation between 140 series promotional traffic and 160 series service or transactional traffic. The same dialler instance cannot route both call types through the same number pool, which is the technical standard regulators and auditors now require. Second, FreJun’s DLT integration handles template registration, Template ID management, and version control for robocall scripts. When a script changes, the platform automatically flags the need for a fresh DLT submission before the updated template goes live. Third, FreJun supports the OAP notification documentation workflow, generating the advance written notification records that Regulation 4 now requires.

Additionally, FreJun integrates with HubSpot, Zoho, Salesforce, and LeadSquared. CDR logging, consent records, and Template ID-to-call mapping are maintained in an auditable form. This supports reviews by sectoral regulators such as RBI and SEBI. For the broader BFSI compliance picture, see our BFSI communication compliance guide for 2026. Our 160 series vs 140 series analysis covers the number framework in full.

Frequently Asked Questions

What is the difference between a 140 series and 160 series number for robocalls in India?

The 140 series is for promotional and telemarketing calls only, including promotional robocalls. The 160 series is for service and transactional calls only, including OTPs, EMI alerts, and account notifications. Promotional robocalls placed from a 160 number, or service robocalls from a 140 number, are both violations of TCCCPR. BFSI entities must use the 1601 sub-prefix for service and transactional calls.

What is the penalty for using an auto-dialer without notifying the Originating Access Provider?

Failing to notify the OAP before using auto-dialer or robocall technology is a TCCCPR violation. The penalty structure runs from Rs 2,00,000 for the first violation to Rs 10,00,000 per instance for third and subsequent violations. Additionally, 5 valid consumer complaints in any rolling 10-day period triggers a 15-day bar on all outgoing services. Subsequent breaches result in full disconnection of all resources for up to one year.

How does an entity apply for a 140 series number to run automated promotional campaigns?

The entity must register as a telemarketer on the DLT platform through a licensed Telecom Service Provider. The TSP verifies the entity’s eligibility, including physical verification and biometric authentication of authorised persons under the 2025 Schedule I amendments. Once registered, the entity receives a Header ID, and the OAP assigns the 140 series number for outbound promotional calling. DLT template registration for each script follows separately.

Are AI-generated voice calls treated as robocalls under TRAI rules?

Yes. AI-generated voice calls fall within the TCCCPR robocall definition. They deliver a voice message without a live human on the calling side at delivery time. The OAP notification obligation, automated-call disclosure, DLT template registration, and number-series restrictions all apply equally to AI-voice calls. They apply in the same way as to traditional pre-recorded robocalls. TRAI is separately considering AI-specific disclosure amendments.

Can a robocall on the 140 series include a service message as well as a promotional offer?

No. Under the TCCCPR Second Amendment (12 February 2025), mixing promotional content with service or transactional content in any single communication classifies the entire communication as promotional. The full promotional compliance stack applies, including explicit consent, DND filtering, and a promotional DLT template. There is no partial classification for mixed-content calls.

What disclosure must a robocall include at the start of the call?

Furthermore, TRAI’s 2025 amendment requires senders to disclose, at the start of the call, that the call is automated (auto-dialer or robocall). The disclosure should also identify the entity placing the call. This customer-facing obligation is separate from, and in addition to, the back-end advance notification to the Originating Access Provider. Importantly, both must be satisfied before automated calling begins.

Does the 30-minute transactional call window apply to OTPs delivered by robocall?

Yes. The TCCCPR Second Amendment limits transactional communications to those triggered within 30 minutes of a customer-initiated event. An OTP delivered by robocall must therefore be dispatched within 30 minutes of the customer’s login or transaction attempt. Calls beyond that window are treated as service communications and require the corresponding consent stack, including a valid service DLT template on the 160 series.

Key Takeaways

  • The TCCCPR Second Amendment (12 February 2025) introduced a mandatory advance written notification to the Originating Access Provider before any sender deploys auto-dialers or robocalls. Entities must file this before deployment, not after the factly.
  • Promotional 140 series auto dialer and robocall traffic must use the 140 series exclusively. Service and transactional robocalls must use the 160 series, with BFSI entities using the 1601 sub-prefix.
  • Mixing promotional content with service or transactional content in a single robocall classifies the entire call as promotional, triggering the full promotional compliance stack.
  • Every robocall script must be registered as a DLT content template before use, and the Template ID the dialler must pass in call signalling for every outbound automated call.
  • Penalties run from Rs 2,00,000 (first violation) to Rs 10,00,000 per instance (third and subsequent), with potential blacklisting of all telecom resources for up to one year.
  • AI-generated voice calls are subject to the same rules as traditional robocalls under the current framework, with additional AI-specific amendments under consideration by TRAI.
  • Consumer-facing disclosure at the start of every automated call is mandatory under the 2025 amendment, independent of the OAP notification obligation.

For Any Questions Reach Out to Our Legal Team

The 2025 auto-dialer notification requirement is new territory for most compliance teams. FreJun’s legal team can review your current setup and identify gaps against the Regulation 4 obligation. They can help you get documentation in place before your next campaign launches.

Compliance Disclaimer

Disclaimer: This article is published for informational purposes only and represents FreJun’s understanding of the relevant legal and regulatory position based on its own independent research and interpretation of publicly available materials. It should not be construed as legal advice, legal opinion, or regulatory guidance. Readers are encouraged to seek independent legal counsel or consult the appropriate regulatory authorities before taking any action based on the information contained herein. While reasonable efforts have been made to ensure the accuracy and completeness of the information presented, laws, regulations, interpretations, and enforcement positions may evolve or vary based on specific facts and circumstances. FreJun does not warrant that the contents are free from inaccuracies, omissions, or inadvertent errors and shall not be responsible or liable for any misinformation, inaccuracies, or reliance placed upon the contents of this article, whether published knowingly or unknowingly.

References and Sources

About the Author: Nimish Gavali is a Legal and Compliance Analyst and appointed Data Protection Officer (DPO) with prior experience practising before the Hon’ble Bombay High Court. Having transitioned into a corporate role, he advises on telecom regulation, digital compliance, data governance, and customer communication frameworks. His work spans TRAI regulations, DoT licensing, the TCCCPR 2018 and related amendments, DLT registration, and the 160 and 140 series numbering framework, with a focus on BFSI and communication platforms navigating compliant customer-outreach architectures. Prior to his in-house role, he worked on regulatory, civil, and commercial matters before the Bombay High Court. He holds an LL.B. from Government Law College, Mumbai, an LL.M. in Business and Corporate Law, and a Diploma in Cyber Laws. Connect on LinkedIn