Healthcare Outbound Calls in India: Which Number Series Applies in 2026?

Key Facts at a Glance

Item	Detail
Primary regulation	TCCCPR, 2018 (Second Amendment, 12 Feb 2025)
Governing bodies	TRAI, DoT, IRDAI (for health insurers)
1601 mandate applies to	IRDAI-regulated health insurers (deadline: 15 Feb 2026)
Hospitals, clinics, telemedicine	Must use 140-series for promotional calls; service calls via 160-series if eligible or via DLT-registered 10-digit numbers (interim)
First-violation penalty	Rs 2,00,000 per instance
Blacklist trigger	5 valid complaints in any rolling 10-day period
Transactional call window	Within 30 minutes of the patient-initiated event
RBI collection-call hours analogy	Healthcare service calls: recommended 08:00-19:00 IST (best practice)

• The 160-series framework covers service and transactional voice calls. IRDAI-regulated health insurers must migrate to 1601 by 15 February 2026 (TRAI Direction, PRID 2205350).
• Hospitals, diagnostic chains, and telemedicine platforms are not currently under the 1601 mandate, but they cannot use standard 10-digit mobile numbers for commercial calls without DLT registration.
• Appointment reminders, OTP calls, discharge alerts, and lab-result notifications qualify as service or transactional calls under TCCCPR and must use registered templates on the DLT platform.
• Promotional calls (health camps, package offers, awareness campaigns) must use the 140-series and cannot be routed through the 160-series under any circumstance.
• Non-compliance can result in a one-year blacklist across all telecom resources, Rs 10,00,000 per repeat violation, and classification as an unregistered telemarketer.

In this article:

• Key Facts at a Glance
• What Is a Healthcare Outbound Call Under Indian Telecom Law?
• Which Number Series Applies to Healthcare Outbound Calls in India?
• Health Insurers: The 1601 Mandate and What It Means
• Hospitals, Clinics, and Diagnostic Chains: Where Do They Stand?
• Telemedicine Platforms: A Distinct Compliance Position
• DLT Registration and Template Compliance for Healthcare Calls
• Penalties for Non-Compliant Healthcare Calling
• How FreJun Helps Healthcare Entities Stay Compliant
• Frequently Asked Questions
• Key Takeaways
• Compliance Disclaimer
• References and Sources

Quick Answer: Healthcare outbound calls in India fall under two number series. IRDAI-regulated health insurers must use the 1601 series by 15 February 2026. Hospitals, clinics, and telemedicine platforms currently use the 160-series for eligible service calls or DLT-registered numbers for transactional calls, while promotional calls must always use the 140-series.

What Is a Healthcare Outbound Call Under Indian Telecom Law?

Healthcare outbound calls in India fall under a strict regulatory framework. Specifically, the Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) govern every commercial voice call made to an Indian consumer, and healthcare entities are not exempt. In fact, hospitals, clinics, and health insurers generate some of the highest volumes of outbound calls in India, covering appointment reminders, OTP delivery, lab results, discharge follow-ups, and promotional health-camp announcements.

Additionally, the Department of Telecommunications introduced the 160-series numbering framework on 30 May 2024 (PRID 2022249) specifically to separate service and transactional calls from promotional traffic. Therefore, this framework directly affects how healthcare entities design their outbound calling infrastructure.

In my practice advising telecom-sector clients, I see healthcare organisations consistently underestimate their TCCCPR obligations. Specifically, most assume that because they are not a bank or insurer, the 160-series rules do not apply to them. That assumption is partially correct but strategically dangerous, as I will explain in each section below.

Service Calls vs Transactional Calls: The Critical Distinction

Specifically, the TCCCPR draws a hard line between service calls, transactional calls, and promotional calls. Each category carries different obligations.

• Service call: Made with consent or via a registered template to facilitate, complete, or confirm a transaction the patient has already consented to. For example, appointment reminders and discharge follow-ups qualify as service calls.
• Transactional call: A non-promotional call to a patient triggered by a patient-initiated action, such as an OTP for a portal login or a booking confirmation. Under the Second Amendment, 2025, the call must be made within 30 minutes of the triggering event.
• Promotional call: Any call whose purpose is to market a product, service, or offer. For instance, health-camp announcements, package promotions, and wellness program solicitations fall here. These must use the 140-series only.

Specifically, the 30-minute window for transactional calls is one of the most violated rules I encounter. A hospital that calls a patient two hours after booking confirmation to “confirm the appointment” is no longer in the transactional category. That call is a service call and needs a properly registered template.

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Which Number Series Applies to Healthcare Outbound Calls in India in 2026?

Notably, the answer depends entirely on the type of healthcare entity making the call. The 160-series framework does not apply uniformly to all healthcare providers. Instead, it follows the regulatory oversight structure that the DoT and TRAI have established.

The Three Relevant Number Series at a Glance

Number Series	Permitted Use	Healthcare Application
140xxxxxxx	Promotional and telemarketing calls only	Health camps, package offers, wellness campaigns
160xxxxxxx (general)	Service and transactional calls by eligible Principal Entities	Appointment reminders, OTPs, lab results (where entity is eligible)
1601xxxxxxx	Service and transactional calls by RBI, SEBI, PFRDA, IRDAI-regulated financial entities	Health insurance OTPs, policy reminders, claim status calls (IRDAI entities only)

Therefore, hospitals and clinics not regulated by any of the four financial regulators (RBI, SEBI, PFRDA, IRDAI) are not currently eligible for the 1601 sub-prefix. However, they remain bound by the broader 160-series principle: service and transactional calls must not originate from standard 10-digit mobile numbers without proper DLT registration and template compliance.

Therefore, what this means for your compliance team is straightforward. Map every outbound call type your organisation makes to one of three categories: promotional (140-series), service (160-series or DLT-registered 10-digit, depending on eligibility), or transactional (same rule, plus the 30-minute window). This mapping exercise should precede any infrastructure procurement decision.

Health Insurers: The 1601 Mandate and What It Means

Among healthcare entities, health insurers regulated by the Insurance Regulatory and Development Authority of India (IRDAI) face the clearest and most urgent compliance deadline. TRAI issued a Direction on 16 December 2025 (PRID 2205350) mandating that all IRDAI-regulated entities adopt the 1601 numbering series by 15 February 2026 for service and transactional voice calls.

Furthermore, by December 2025, approximately 570 entities had already adopted the 1600 series, subscribing to over 3,000 numbers across all TSPs, as noted in the PRID 2205350 press release. Indeed, health insurers were part of this voluntary adoption wave before the mandate converted the obligation into a hard deadline.

What Calls Do Health Insurers Typically Make?

In practice, health insurers generate large volumes of outbound voice calls across several categories. Specifically, each category requires a specific compliance treatment.

• Premium reminder calls: These are service calls. They must use a DLT-registered template and, post-mandate, must originate from a 1601 number.
• Claim status update calls: Also service calls. The same template and number-series rules apply.
• OTP and authentication calls: Transactional calls. Must be made within 30 minutes of the customer-initiated event (for example, a portal login or a claims portal submission).
• Policy renewal upsell calls: Promotional calls. These must use the 140-series, regardless of whether the entity holds a 1601 number.
• Wellness program announcements: Promotional calls. Again, 140-series only.

Furthermore, using a 1601 number to make a policy renewal upsell call is a direct TCCCPR violation. The DoT allocation undertaking requires that 1601 numbers be used strictly for service and transactional calls. A single promotional call from a 1601 number breaches the allocation undertaking and triggers TCCCPR penalty provisions independently of any other violation.

Indeed, in practice, health insurers find the most significant operational risk in their outbound collections and renewal teams. These teams often blend service information with a soft promotional nudge in the same call script. That blended approach is now legally untenable under the 1601 framework.

Hospitals, Clinics, and Diagnostic Chains: Where Do They Stand?

Currently, hospitals, multi-speciality chains, standalone clinics, and diagnostic laboratories are not regulated by RBI, SEBI, PFRDA, or IRDAI. Therefore, they are not subject to the 1601 mandate as it currently stands. However, this does not mean they operate freely without compliance requirements.

Promotional Calls from Hospitals: The 140-Series Obligation

Specifically, any outbound call made by a hospital for marketing purposes must use a 140-series number. This applies to health-camp announcements, annual health checkup package promotions, new department launch announcements, and any other call whose primary purpose is to generate commercial interest.

Moreover, DoT allocated the 140xxxxxxx series specifically for promotional and telemarketing calls. Using a standard 10-digit mobile number for these calls, even a registered corporate mobile, makes the entity liable to be treated as an unregistered telemarketer under TCCCPR. The enforcement progression for unregistered telemarketers starts with a warning, escalates to a usage cap of 20 outgoing calls per day for six months, and then reaches full disconnection of all telecom resources.

Service and Transactional Healthcare Outbound Calls: Current Framework

Specifically, for appointment reminders, OTP delivery, discharge follow-up calls, and lab-result notifications, hospitals currently have two compliant options. First, they can register as a Principal Entity on the DLT platform, register their call templates, and use DLT-registered numbers for service calls. Second, as the DoT 160-series framework expands to cover sectors beyond BFSI (which remains a matter of regulatory development to watch), hospitals may become eligible for 160-series allocation in future phases.

Furthermore, the DoT Press Release of 30 May 2024 (PRID 2022249) describes the 160xxxxxxx series as allocated for service and transactional calls by Principal Entities. The press release notes that financial entities regulated by RBI, SEBI, PFRDA, and IRDAI start from 1601. This language implies that other verified Principal Entities may access different sub-prefixes within the broader 160 range, though formal allocation guidelines for non-BFSI sectors have not been separately notified as of the date of this article.

In practice, what this matters for your compliance team is: hospitals and diagnostic chains must, at minimum, complete DLT registration, register all call templates, and ensure that appointment reminder and OTP calls use DLT-registered numbers. Calling from an unregistered mobile number, even for a genuine appointment reminder, creates regulatory exposure.

See how FreJun helps hospitals and diagnostic chains configure compliant outbound calling workflows, from DLT registration through to CDR logging. Most healthcare teams complete the initial setup within a week. Book a demo to walk through the exact workflow for your organisation.

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Telemedicine Platforms: A Distinct Compliance Position

In contrast, telemedicine platforms occupy a distinct position in this framework. They combine characteristics of healthcare service providers, technology intermediaries, and in some cases, insurance-linked service providers.

How Telemedicine Platforms Should Categorise Their Calls

Specifically, for compliance purposes, a telemedicine platform must first determine whether it functions as the Principal Entity making the call, or as an outsourced service provider acting on behalf of another Principal Entity (such as a hospital or health insurer). This distinction matters because TCCCPR’s vicarious liability provisions hold the Principal Entity responsible for the conduct of its agents.

Additionally, when a health insurer links a telemedicine platform to its services (for example, a wellness app as an IRDAI-regulated insurer’s value-added product), the 1601 mandate applies to calls the platform makes on the insurer’s behalf. Therefore, the platform must use the insurer’s allocated 1601 number pool, not its own unregistered numbers.

Furthermore, telemedicine platforms that issue OTPs for patient authentication always generate transactional calls. The 30-minute window rule under the Second Amendment, 2025 applies here. An OTP call placed 45 minutes after the patient logged in falls outside the transactional window. Your team must treat it as a service call with a corresponding registered template.

Telemedicine and the DPDP Act, 2023 Intersection

Notably, telemedicine platforms process sensitive personal data, including health records, diagnoses, and prescription information. Therefore, calls involving patient health data sit at the intersection of TCCCPR and the Digital Personal Data Protection Act, 2023 (DPDP Act). The DPDP Act requires a lawful basis for every processing activity, and an outbound call that references a patient’s health condition constitutes processing of sensitive personal data.

In practice, therefore, telemedicine platforms must document the lawful basis (typically consent under Section 7 of the DPDP Act, 2023) for every call that references health information. Consent records must align with the Digital Consent Acquisition (DCA) framework on the DLT platform.

DLT Registration and Template Compliance for Healthcare Calls

Regardless of entity type, every organisation responsible for healthcare outbound calls in India must register on the Distributed Ledger Technology (DLT) platform operated by access providers. This is not optional, and it applies to hospitals, diagnostic chains, telemedicine platforms, and health insurers equally.

What Healthcare Entities Must Register on DLT

Specifically, the DLT registration requirement covers several distinct elements. First, the entity itself must register as a Principal Entity (PE). Second, your team must link any telemarketer or outsourced calling partner to the PE registration. Third, every voice script, including IVR openers, agent introductions, appointment reminder scripts, and OTP delivery phrases, must be pre-registered as a content template carrying a unique Template ID.

Consequently, calling with an unregistered template, an outdated template, or a blacklisted template is a TCCCPR violation regardless of whether the originating number is itself a valid allocation. In my experience advising clients in the telecom space, the DLT template registration step is the one that consistently takes the longest for first-time registrants, often two to three weeks. Healthcare entities should begin this process well before their operational launch or their compliance deadline.

Specifically, each template must carry a unique Template ID that passes through the call signalling layer. The Telecom Service Provider’s switching infrastructure validates this ID in real time. A call without a valid Template ID fails at the network level, which means patient OTPs simply do not reach their destination. This operational consequence is often the most effective argument for prompt compliance within healthcare IT teams.

Consent Requirements for Healthcare Voice Calls

Notably, the Second Amendment to TCCCPR, dated 12 February 2025, significantly tightened consent rules. For healthcare entities, the following consent principles apply.

• Implicit consent: Valid for service calls during the period of the patient-provider relationship (for example, from registration to discharge and reasonable follow-up period).
• Explicit consent: Required for calls where no ongoing patient relationship exists. Valid for only 7 days from grant for the specific stated purpose.
• Opt-out lockout: Once a patient opts out, the healthcare entity must not contact them again for the same purpose for 90 days.
• Auto-dialer and robo-call disclosure: Any call using an automated dialer or pre-recorded voice must disclose this at the start of the call.

What this means for your compliance team is critical: your compliance team must store patient consent records in an auditable format, mapped to the DCA framework on the DLT platform, and aligned with the DPDP Act, 2023 requirements. For example, a patient who consents to appointment reminders during registration has not thereby consented to promotional calls about unrelated health packages.

Penalties for Non-Compliant Healthcare Calling

Notably, healthcare entities making healthcare outbound calls in India face the same multi-layered penalty structure that applies to BFSI entities, with one important addition: IRDAI-regulated health insurers also face sectoral regulatory action from IRDAI itself. Below is the complete penalty map relevant to healthcare.

TCCCPR Financial Penalties (Per Instance)

Specifically, under the Second Amendment, 2025, the following graded financial penalties apply per violation instance.

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

Furthermore, these penalties apply separately for registered and unregistered senders. Furthermore, they are in addition to any financial penalty for invalid complaint closure or non-fulfillment of other TCCCPR obligations.

Blacklisting and Service Disconnection

However, the blacklisting provisions are operationally more severe than the financial penalties for a healthcare entity. The blacklist trigger is 5 valid consumer complaints in any rolling 10-day period. Once triggered, the consequences escalate as follows.

• First violation of complaint threshold: Outgoing services on all telecom resources of the sender barred for 15 days.
• Subsequent violations: All telecom resources, including PRI and SIP trunks, disconnected across all access providers for one year. TRAI then blacklists the entity.

Consequently, for a hospital or telemedicine platform, a one-year blacklist is operationally catastrophic. Patient OTPs cannot be delivered. Appointment confirmation calls cannot be made. Doctor-on-call routing fails. Therefore, the operational cost of a single compliance cycle failure materially exceeds the cost of a compliant infrastructure investment.

Treatment as Unregistered Telemarketer

Specifically, if a healthcare entity makes commercial calls from a standard 10-digit mobile number without DLT registration, TRAI classifies those calls as Unsolicited Commercial Communication from an Unregistered Telemarketer. The enforcement progression for unregistered telemarketers starts with a warning, then escalates to a usage cap of 20 outgoing voice calls per day for six months, and finally reaches disconnection of all telecom resources.

Furthermore, IRDAI-regulated health insurers that fail to migrate to the 1601 series by 15 February 2026 face this classification for all service and transactional calls made thereafter. The IRDAI may also take independent sectoral action under Sections 102 to 105B of the Insurance Act, 1938 for conduct that creates consumer harm or reputational risk.

How FreJun Helps Healthcare Entities Stay Compliant

Overall, FreJun provides a cloud telephony and AI-powered calling platform designed specifically for regulated calling environments in India. For teams managing healthcare outbound calls in India, this means appointment reminder workflows, OTP routing, and DLT template management all handled through one platform.

What FreJun Provides for Healthcare Calling

• DLT-integrated platform: FreJun handles Principal Entity registration, telemarketer linkage, and template registration workflows. As a result, this removes the most time-consuming compliance step from your IT team’s plate.
• Number-series routing: The platform enforces routing segregation at the system level. Promotional calls cannot leak into the 160-series trunk, and vice versa. Importantly, this is not a policy statement but a technical constraint enforced in the dialer logic.
• CDR logging and audit trail: Every call generates a full Call Detail Record mapped to the Template ID invoked. This audit trail supports TCCCPR record-keeping obligations and, for health insurers, the IRDAI’s IT audit requirements.
• Consent management: FreJun’s consent layer aligns with the DCA framework, allowing healthcare entities to record, store, and produce patient consent records on demand.
• CRM integrations: FreJun connects with HubSpot, Zoho, Salesforce, and Leadsquared. Consequently, appointment reminder triggers can fire automatically from your patient management system within the 30-minute transactional window.

In practice, therefore, FreJun’s onboarding team guides healthcare entities through the entity-type determination (IRDAI-regulated insurer vs hospital vs telemedicine platform), the appropriate number-series selection, and the DLT template registration timeline. Most healthcare teams are operationally live within one to two weeks of onboarding.

That said, FreJun is not a Telecom Service Provider or TSP. It operates as a cloud telephony platform that procures capacity from licensed TSPs and routes calls through their infrastructure. Healthcare entities should verify their own Principal Entity registration and their chosen TSP’s license status through the SARAL SANCHAR portal independently.

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Frequently Asked Questions

160 series vs 140 series for healthcare: what is the difference?

TRAI reserves the 140-series for promotional and telemarketing calls only. TRAI reserves the 160-series, including the 1601 sub-prefix, for service and transactional calls. Therefore, healthcare entities must use 140-series numbers for health-camp promotions and package offers, and the appropriate 160-series or DLT-registered number for appointment reminders, OTPs, and lab-result calls. Mixing the two series is a direct TCCCPR violation.

Do hospitals need to migrate to the 1601 series by February 2026?

No. Specifically, the 1601 mandate issued by TRAI on 16 December 2025 (PRID 2205350) applies only to IRDAI-regulated entities, not to hospitals or standalone clinics. However, hospitals must still register on the DLT platform and use DLT-registered numbers for all commercial calls, including appointment reminders and OTPs, to avoid being treated as unregistered telemarketers.

What is the penalty for a hospital using a regular mobile number for appointment reminder calls?

TRAI may classify a hospital using an unregistered 10-digit mobile number for appointment reminders as an Unregistered Telemarketer under TCCCPR. Specifically, penalties begin with a warning, escalate to a 20-call-per-day usage cap for six months, and reach full disconnection of all telecom resources. Financial penalties reach Rs 10,00,000 per instance for repeat violations.

How does a healthcare entity apply for a 160-series number?

First, a healthcare entity must register as a Principal Entity on the DLT platform. It must then apply through its Telecom Service Provider (TSP) for a 160-series allocation. The TSP must verify eligibility before assigning the number, as per the DoT Press Release dated 30 May 2024 (PRID 2022249). Additionally, non-BFSI entities should confirm current eligibility criteria with their TSP directly.

Can a telemedicine platform use its own number for OTP calls if it is linked to a health insurer?

No. If a telemedicine platform makes OTP calls on behalf of an IRDAI-regulated insurer, those calls must originate from the insurer’s allocated 1601 number pool. The platform cannot substitute its own unregistered numbers. The insurer remains vicariously liable for the platform’s calling conduct under TCCCPR and the IRDAI outsourcing framework.

Are health-camp promotional calls legal in India, and which number do they use?

Yes. Specifically, health-camp promotional calls are legal if the caller is registered on the DLT platform, uses a 140-series number, and calls only subscribers who have not registered a DND preference for healthcare promotions. The 160-series is strictly prohibited for promotional use. TRAI prohibits any promotional content on a 160-series call, even as a brief mention during a service call.

What happens if a health insurer misses the 15 February 2026 1601 migration deadline?

Service and transactional calls from a standard 10-digit number after the 15 February 2026 deadline will be classified as Unsolicited Commercial Communication from an Unregistered Telemarketer. This exposes the insurer to TCCCPR penalties starting at Rs 2,00,000, potential IRDAI sectoral action under Sections 102 to 105B of the Insurance Act, 1938, and ultimately one-year blacklisting of all telecom resources if complaint thresholds are crossed.

Key Takeaways for Healthcare Outbound Calls in India

• IRDAI-regulated health insurers must migrate to the 1601 series by 15 February 2026 for all service and transactional calls (TRAI Direction, PRID 2205350, 16 December 2025).
• Hospitals, clinics, and diagnostic chains are not subject to the 1601 mandate but must complete DLT registration and use registered templates for all commercial calls.
• The 140-series applies universally to promotional healthcare calls, including health-camp announcements and package promotions.
• The TCCCPR transactional call window is 30 minutes from the patient-initiated event. Calls placed after this window must use a service-call template.
• Additionally, your entity must respect patient opt-out rights for 90 days. Re-contacting an opted-out patient within this period is a direct TCCCPR violation.
• Furthermore, TRAI triggers blacklisting after just 5 valid complaints in 10 days and disconnects all telecom resources for one year.
• Finally, telemedicine platforms acting on behalf of health insurers must use the insurer’s 1601 number pool, not their own numbers, and the insurer bears vicarious liability.

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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

• DoT Press Release, 30 May 2024 (PRID 2022249): pib.gov.in
• TRAI Direction, 19 November 2025 (PRID 2191647): pib.gov.in
• TRAI Direction (IRDAI), 16 December 2025 (PRID 2205350): pib.gov.in
• TCCCPR Second Amendment, 12 February 2025: trai.gov.in (PDF)
• TCCCPR 2018: trai.gov.in
• DPDP Act, 2023: meity.gov.in
• SARAL SANCHAR Portal (TSP License Verification): saralsanchar.gov.in
• FreJun BFSI Communication Compliance Guide: frejun.com
• FreJun TCCCPR 2018 Compliance Guide: frejun.com
• FreJun 160 Series vs 140 Series Guide: frejun.com

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