How to Migrate from 10-Digit Numbers to 160 Series: BFSI Ops Guide

The 160 series migration is now mandatory for every BFSI entity regulated by RBI, SEBI, IRDAI, or PFRDA. TRAI Direction dated 19 November 2025 (PRID 2191647) set the rules. Consequently, all service and transactional voice calls must move from 10-digit mobile numbers to the 1600 series by phase-wise deadlines. Entities that miss their deadline face immediate consequences. Specifically, TRAI classifies them as Unregistered Telemarketers, financial penalties starting at Rs 2,00,000 per violation, and a possible one-year telecom blacklist. This step-by-step ops guide walks your compliance and operations team through every stage of the 160 series migration process, from eligibility checks to go-live.

160 Series Migration: Key Facts at a Glance

Item	Detail
Regulation	TCCCPR, 2018 (Second Amendment, 12 Feb 2025)
Governing body	TRAI and DoT
Applies to	All BFSI entities regulated by RBI, SEBI, IRDAI, PFRDA making service or transactional voice calls
Number series required	1600xxxxxxx (1601xxxxxxx for financial entities)
First-violation penalty	Rs 2,00,000
Blacklist trigger	5 valid complaints within any rolling 10-day period
Maximum blacklist duration	1 year across all telecom resources, all TSPs
SEBI deadline (Mutual Funds and AMCs)	15 February 2026
SEBI deadline (Qualified Stockbrokers)	15 March 2026
Voluntary adopters as of Nov 2025	485 entities covering over 2,800 numbers

• TRAI has mandated the 160 series migration for all RBI-, SEBI-, IRDAI-, and PFRDA-regulated entities, with deadlines starting February 2026.
• Continuing to use 10-digit numbers after your deadline means TRAI classifies each call as Unsolicited Commercial Communication, with penalties starting at Rs 2,00,000 and possible one-year blacklisting.
• The 160 series migration involves five steps: eligibility check, TSP allocation, DLT template registration, dialer reconfiguration, and audit trail setup.
• The 1601xxxxxxx sub-prefix is for financial entities regulated by RBI, SEBI, PFRDA, and IRDAI. It gives consumers a clear signal that the call is legitimate.
• FreJun handles the technical migration layer so your compliance team can focus on substantive regulatory obligations.

Quick Answer: To complete the 160 series migration, a BFSI entity follows five steps. First, verify regulatory eligibility. Next, apply to a licensed TSP for a 1600-series allocation. Then register all voice templates on the DLT platform. Finally, reconfigure the dialer and set up CDR and consent logs before the applicable TRAI deadline.

Table of Contents

1. Why Must BFSI Entities Complete the 160 Series Migration?
2. Who Must Migrate to 160 Series and by When?
3. 160 Series vs 140 Series: What Is the Difference?
4. Step-by-Step 160 Series Migration Guide for BFSI Teams
5. How to Register DLT Templates for Your 160 Series Number
6. How to Reconfigure Your Dialer and CRM After 160 Series Migration
7. Consent Management and CDR Logging After 160 Series Migration
8. What Happens to Recovery Agents and BPOs During 160 Series Migration?
9. Penalties for Not Completing the 160 Series Migration
10. How FreJun Supports Your 160 Series Migration
11. Frequently Asked Questions
12. Key Takeaways
13. Compliance Disclaimer
14. References and Sources

Get Legal Guidance

Migration deadlines are active. FreJun’s compliance team guides BFSI entities through each step of the 160 series migration, from eligibility checks to DLT registration. Most teams finish the core process in two to three weeks with the right support.

Why Must BFSI Entities Complete the 160 Series Migration?

BFSI entities must complete the 160 series migration because TRAI has banned service and transactional voice calls from standard 10-digit mobile numbers. After the applicable deadline, every such call becomes a TCCCPR violation. Moreover, TRAI can classify the entity as an Unregistered Telemarketer. That classification triggers escalating penalties and, ultimately, a one-year blacklist of all telecom resources.

The Fraud Problem That Made 160 Series Migration Necessary

The 140xxxxxxx series was first allocated for promotional, service, and transactional calls. However, consumers quickly linked 140 numbers with spam. They stopped answering them. Additionally, genuine banks and NBFCs then shifted to 10-digit mobile numbers for OTPs and account alerts. This shift created an opening for fraudsters. Specifically, scammers also used 10-digit numbers to copy bank agents, and consumers had no way to tell the difference.

Therefore, the Department of Telecommunications (DoT) created the 160xxxxxxx series through its press release dated 30 May 2024 (PRID 2022249). The DoT stated that service and transactional calls from financial entities regulated by RBI, SEBI, PFRDA, and IRDAI would start from 1601. This prefix gives consumers a clear cue. Specifically, a call from 1601xxxxxxx is a verified service call from a regulated financial body, not a fraudster with a SIM card.

Furthermore, industry reports show roughly 147 million spam complaints in India in 2024. That scale of consumer harm is exactly what the 160 series migration aims to reduce. For your compliance team, this means the migration is not just a checkbox: it is your entity’s role in rebuilding consumer trust in voice communication.

Who Must Complete the 160 Series Migration and by When?

Every entity regulated by RBI, SEBI, IRDAI, or PFRDA that makes outbound service or transactional voice calls must complete the 160 series migration. The obligation belongs to the Principal Entity itself. Vendors and recovery agencies acting on its behalf are also covered, but the Principal Entity is legally responsible for their compliance.

Phase-Wise 160 Series Migration Deadlines

The TRAI Direction dated 19 November 2025 (PRID 2191647) set the following deadlines for SEBI-regulated entities:

Entity Category	Regulator	160 Series Migration Deadline
Mutual Funds and AMCs	SEBI	15 February 2026
Qualified Stockbrokers (QSBs)	SEBI	15 March 2026
RBI-regulated entities	RBI	Subsequent phases per PRID 2191647
IRDAI-regulated insurers	IRDAI	Per PRID 2205350 (16 Dec 2025)
PFRDA-regulated pension funds	PFRDA	Subsequent phases per PRID 2191647

Therefore, check the exact phase tier for your entity against the operative TRAI Direction text. In fact, secondary commentary on NBFC cut-offs varies. Your legal counsel and TSP should confirm your specific deadline before you start planning the 160 series migration.

In my work advising telecom-sector clients, I have seen entities assume a later phase based on asset size, only to find the Direction text sorts them by licence type, not balance sheet size. That mistake can be costly. Verify your phase first.

485 Entities Have Already Finished Their 160 Series Migration

As of November 2025, 485 entities had already completed the 160 series migration voluntarily, subscribing to over 2,800 numbers (TRAI Direction, PRID 2191647, 19 November 2025). Indeed, their early adoption proves the process works within short timelines. It also gave TRAI the confidence to set firm phase-wise deadlines.

160 Series vs 140 Series: What Is the Difference?

The 160 series and the 140 series serve different purposes. The key rules come from the Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) and the Second Amendment dated 12 February 2025. They are not interchangeable. Understanding this gap is central to planning a correct 160 series migration.

Feature	140 Series	160 Series (1600/1601)
Permitted use	Promotional and telemarketing calls only	Service and transactional calls only
Who can hold it	Registered telemarketers and Principal Entities for campaigns	Verified Principal Entities; 1601 sub-prefix for RBI, SEBI, IRDAI, PFRDA entities
Consumer perception	Linked to spam; low answer rates	Verified call; building consumer trust
Can carry OTPs?	No	Yes, as transactional call within 30 minutes of customer event
Can carry EMI reminders?	No	Yes, as a service call under a registered template
Can carry promotions?	Yes	Strictly banned
DLT template required?	Yes	Yes
Penalty for misuse	Rs 2,00,000 first violation	Rs 2,00,000 first violation plus blacklisting risk

For your compliance team, the practical rule is simple: use 140 for promotions and 1600/1601 for every OTP, EMI reminder, account alert, and collection follow-up. Your routing logic must enforce this split at the system level. A written policy alone is not enough.

Step-by-Step 160 Series Migration Guide for BFSI Teams

The 160 series migration involves five core steps. Each step has a clear owner, a clear output, and dependencies you must sequence correctly. Skipping any step creates gaps that regulators and auditors will find. Below is the full process.

Step 1: Verify Regulatory Eligibility Before Starting 160 Series Migration

First, confirm that your entity holds a valid licence from its sectoral regulator (RBI, SEBI, IRDAI, or PFRDA) before contacting any TSP. Your TSP must verify this before assigning a 160 number. This obligation comes from the DoT Press Release dated 30 May 2024 (PRID 2022249).

• Get a certified copy of your current regulatory registration or licence certificate.
• Confirm the licence is active and not under suspension.
• Find your phase deadline from the TRAI Direction (PRID 2191647 for RBI, SEBI, PFRDA entities; PRID 2205350 for IRDAI entities).
• Check your entity category against the operative Direction text, not secondary commentary.
• If you have subsidiaries or group companies, each must go through separate eligibility checks and get its own allocation.

Additionally, confirm that your TSP holds a valid Unified Licence (UL) or UL-VNO authorisation. Check this on the SARAL SANCHAR portal at saralsanchar.gov.in. An unlicensed intermediary cannot lawfully assign 160 series numbers.

Step 2: Apply to Your TSP for a 1600 Series Number as Part of the 160 Series Migration

Submit a formal application to your TSP for a 1600 series number. Include your regulatory licence. Also attach a corporate undertaking to use the number only for service and transactional calls under TCCCPR, 2018. Additionally, name the Principal Entity responsible for all calls from the number.

• Request the 1601xxxxxxx sub-prefix if your entity is a financial body regulated by RBI, SEBI, IRDAI, or PFRDA.
• Sign the corporate undertaking on company letterhead with an authorised signatory.
• List the call use-cases (OTP delivery, EMI reminders, account alerts, collection follow-ups).
• Get written confirmation from the TSP of the allocation and sub-prefix assigned.
• Keep all TSP correspondence as part of your audit trail.

Note that a 1600/1601 number is a telecom resource of the State. Your entity does not own it. Therefore, you cannot transfer it, sub-allocate it to group companies, or use it after your regulatory licence expires. You cannot transfer it, sub-allocate it to group companies, or use it after your regulatory licence expires.

Step 3: Complete DLT Registration as Part of the 160 Series Migration Process

DLT registration takes the most calendar time in the 160 series migration. First-time registrants typically spend two to three weeks on DLT on-boarding before templates receive approval. Start DLT registration in parallel with your TSP application. Running both together cuts your total timeline by weeks.

Every voice script your entity uses must be pre-registered as a content template on the DLT platform. Each template carries a unique Template ID. Your dialer must pass this ID in call signalling. Using an unregistered or outdated template is a TCCCPR violation, even if your 1600 number is validly allocated.

• Register your entity as a Principal Entity (PE) on the DLT platform of your access provider.
• Create a separate template for each call use-case: OTP, EMI reminder, account alert, fraud alert, collection follow-up.
• Tag each template with the correct category: transactional or service.
• Get Template IDs for all approved templates before go-live.
• Set a reminder to renew templates before they expire.
• Register outsourced recovery agencies as sub-entities under your PE registration on the DLT platform.

For your compliance team, template management is ongoing, not a one-time task. Blacklisted or expired templates need updating before further use. Each update triggers a fresh approval cycle.

Step 4: Reconfigure Your Dialer as Part of the 160 Series Migration

Technical routing segregation is the rule that trips most entities during the 160 series migration. TCCCPR and DoT guidance are both clear: the same dialer cannot send both 140 promotional traffic and 1600/1601 transactional traffic through the same number pool. You must enforce this at the system level, not just in a policy document.

• Assign your 1600/1601 number to the outbound trunk for service and transactional calls only.
• Remove all 10-digit mobile numbers from the service and transactional call pool before go-live.
• Set your IVR to show the correct 1600/1601 caller ID on every outbound call. Do not mask or overlay it.
• Configure the dialer to pass the Template ID for each call type in the call signalling metadata.
• Run a small-volume pilot before full cutover to confirm routing is correct.
• Log the configuration change with screenshots as part of your audit trail.

Section 42 of the Telecommunications Act, 2023 makes it a criminal offence to tamper with telecommunication identifiers. Furthermore, TRAI’s Calling Name Presentation (CNAP) rules require accurate caller identity on the receiving handset. Both rules ban masking your 1600 number behind any overlay.

Step 5: Set Up Your Audit Trail to Complete the 160 Series Migration

After go-live, your entity must keep a continuous audit trail. These records are your defence in any TRAI complaint or sectoral regulator review. They also matter in any Data Protection Board inquiry under the Digital Personal Data Protection Act, 2023 (DPDP Act).

• Call Detail Records (CDRs): Full CDRs for every call from the 1600 number. Keep them for the period your TSP licence and sectoral regulator require.
• Template IDs: Map each Template ID to the matching CDR entry to show every call used a registered template.
• Consent records: Where consent was the lawful basis, keep the Digital Consent Acquisition (DCA) record from the DLT platform, including consent date, scope, and expiry.
• Complaint logs: Log every TRAI or consumer complaint, the date received, and the resolution date. The blacklist trigger is 5 valid complaints in any rolling 10-day period, so real-time monitoring is essential.

Additionally, call recordings and CDRs of Indian BFSI customers must sit on servers located within India. This follows the RBI Storage of Payment System Data circular dated 6 April 2018 and the DPDP Act, 2023. Document any cross-border processing protocols in writing.

How to Register DLT Templates for Your 160 Series Migration

Notably, DLT template registration for a 1600 series number follows the same platform as SMS template registration. However, the content categories and approval criteria differ for voice templates. Here is the process in detail.

Selecting the Right DLT Platform for Your 160 Series Migration

In India, multiple TSPs run DLT platforms: Airtel, Jio, BSNL, Vodafone Idea, and Tata Communications. Therefore, your entity must register on the platform of your access provider TSP. However, because these platforms are interoperable, templates registered with one TSP are visible to others for routing checks.

Therefore, confirm which TSP allocated your 1600 number, then start PE registration on that TSP’s DLT portal. Some entities use multiple TSPs for their PRI or SIP trunk setup. In that case, treat the TSP that holds your 1600 allocation as your primary DLT registration point.

Template Submission Requirements for 160 Series Migration Compliance

Specifically, each template needs the exact script text, the content category (transactional or service), the intended recipient group, and the expected trigger event. The DLT platform reviewer checks that the script has no promotional language. Any promotional element in a service or transactional template leads to rejection. If you use such a template, it is also a TCCCPR violation.

• Keep transactional templates (OTPs, transaction confirmations) separate from service templates (EMI reminders, account alerts).
• Remove all promotional language from templates submitted for 1600 series use.
• Mark variable fields (customer name, account last four digits) using the approved notation of the DLT platform.
• Submit templates for all call use-cases before go-live. Do not go live with any call type that lacks an approved template.
• Save the template approval confirmation, including Template ID and approval date, as a compliance record.

How to Reconfigure Your Dialer and CRM After 160 Series Migration

Indeed, dialer and CRM reconfiguration is the most technical part of the 160 series migration. It is also where errors are most costly. A call that goes out on a 10-digit number after your deadline is an instant TCCCPR violation.

Dialer Configuration Checklist for 160 Series Migration

• Create a dedicated outbound trunk or campaign profile for your 1600/1601 number in your dialer platform.
• Set the caller ID for every call in that profile to show the 1600/1601 number, not any underlying SIP or PRI number.
• Map the correct DLT Template ID to each campaign or call type in the call metadata.
• Disable or archive all campaigns that previously used 10-digit mobile numbers for service or transactional calls.
• Add a routing rule that blocks any service or transactional call not coming from the 1600/1601 outbound trunk.
• Test caller ID display on both Android and iOS handsets to confirm the 1600/1601 number appears correctly.

CRM Integration Steps for 160 Series Migration

After migration, your CRM (HubSpot, Zoho, Salesforce, Leadsquared, or similar) must log the 1600/1601 number as the source for every service or transactional call record. Additionally, the CRM should capture the Template ID and consent status for each call. This keeps the audit trail inside the system your compliance team already uses.

Furthermore, configure your CRM to flag calls placed outside the 08:00 to 19:00 IST window (for collection or recovery contacts). This follows the RBI Fair Practices Code and RBI Responsible Lending Conduct directions. The flag should stop the call before it goes out, not just note it after the fact.

Similarly, build consent expiry rules into your CRM contact eligibility logic. Explicit consent is valid for only 7 days from the date of grant. A customer who has opted out cannot be contacted for 90 days on the same purpose. These rules come from the TCCCPR Second Amendment dated 12 February 2025. Your CRM must suppress such contacts from outbound call lists before the call attempt.

Consent Management and CDR Logging After 160 Series Migration

Furthermore, post-migration compliance does not stop at go-live. Consent management and CDR logging are ongoing duties under both TCCCPR and the DPDP Act. Failing either area creates dual-regulator risk: TRAI on the telecom side and the Data Protection Board on the data side.

Key Consent Rules After 160 Series Migration

• Implicit consent: Valid only for the life of the contract between the BFSI entity and the customer. When the contract ends, implicit consent ends with it.
• Explicit consent: Valid for 7 days from the grant date for the specific stated purpose.
• Transactional call window: The call must go out within 30 minutes of the customer-initiated event. Calls beyond 30 minutes become service calls and need a different consent basis.
• Opt-out lockout: Once a subscriber opts out, you cannot contact them on the same purpose for 90 days from the opt-out date.
• Auto-dialer disclosure: If the call uses an auto-dialer or robo-call system, your IVR must say so at the start of the call.
• DCA framework: All consent records must align with the Digital Consent Acquisition framework on the DLT platform.

CDR Logging Duties After 160 Series Migration

Moreover, CDR logs must be in an auditable, tamper-proof format. Each entry should include the calling number (your 1600/1601 number), the called number, call date and time, and call duration. Additionally, include the Template ID and the outcome: answered, unanswered, or disconnected. Map each CDR entry to the matching consent record where consent was the basis for the call.

Under Section 7 of the DPDP Act, 2023, your entity as a Data Fiduciary must document the lawful basis for personal data processing. A service or transactional call to your own customer normally falls under processing for a specified legitimate purpose. However, you must still document that basis and keep it for the retention period your sectoral regulator requires.

What Happens to Recovery Agents and BPOs During 160 Series Migration?

Importantly, outsourcing does not remove compliance from the Principal Entity. In practice, the 1600/1601 number belongs to the BFSI entity. Any recovery agency, BPO, or telemarketer acting for that entity must use the entity’s allocated 1600/1601 numbers, not its own pool.

Principal Entity Liability During 160 Series Migration

The Principal Entity bears liability for its agents’ conduct. This covers TCCCPR, the RBI Fair Practices Code, and the RBI Master Direction on Outsourcing of IT Services dated 10 April 2023 (RBI Master Direction, 10 April 2023). If your recovery agency places a collection call from a 10-digit mobile number after your migration deadline, TRAI holds your entity responsible for that breach.

Additionally, individual recovery agents must hold a valid IIBF certification after completing the prescribed 100-hour training programme. Your entity must also keep a board-approved Code of Conduct for recovery agents covering TCCCPR rules, calling hour limits, and banned conduct during collection calls.

Practical Steps for BPO and Recovery Agent 160 Series Migration Compliance

• Send a written directive to every outsourced recovery agency and BPO requiring all calls on your behalf to go through your 1600/1601 number.
• Update outsourcing agreements to add TCCCPR duties: approved DLT templates, calling hour limits, and CDR submission requirements.
• Add a right-to-audit clause in all outsourcing agreements so you can check compliance on demand.
• Request periodic compliance certificates from each BPO confirming they have not used any 10-digit number for service or transactional calls on your behalf.
• Register each outsourced agency as a sub-entity under your PE registration on the DLT platform.

For your operations head, BPO transition timelines must be part of your overall 160 series migration project plan. You cannot go live on your own dialer and ignore your BPO channel. Indeed, both channels must be compliant by your deadline. Both channels must be compliant by your deadline.

Penalties for Not Completing the 160 Series Migration

The penalty structure for failing to complete the 160 series migration is multi-layered. A single non-compliant call pattern can trigger action under telecom law, sectoral regulation, and data protection law at the same time. The practical severity is highest at the disconnection layer.

TCCCPR Financial Penalties for Skipping 160 Series Migration

Violation Instance	Financial Penalty
First violation	Rs 2,00,000
Second violation	Rs 5,00,000
Third and later violations	Rs 10,00,000 per instance

One-Year Telecom Blacklist: The Biggest Risk of Avoiding 160 Series Migration

Beyond financial penalties, TRAI holds a disconnection power that is operationally devastating for any regulated entity. The complaint threshold is 5 valid complaints in any rolling 10-day period. When it triggers, TRAI can bar outgoing services on all telecom resources of the entity for up to one year. This ban covers all TSPs at once. For a bank or NBFC, this means OTPs stop, customer service calls stop, and collections stop. No financial penalty comes close to this in operational impact.

Sectoral Regulator Action After Failed 160 Series Migration

TRAI issued its Direction after Joint Committee of Regulators (JCoR) talks with RBI, SEBI, IRDAI, and PFRDA. As a result, non-migration also exposes your entity to action by its own sectoral regulator. RBI may act under Section 35A of the Banking Regulation Act, 1949. IRDAI may act under Sections 102 to 105B of the Insurance Act, 1938. SEBI may act under Section 15HB of the SEBI Act, 1992. These actions run independently of any TRAI penalty for the same conduct.

Furthermore, non-compliance may also breach personal data rules. For example, calling without a lawful basis or ignoring opt-outs triggers the DPDP Act, 2023. In that case, the Data Protection Board can impose penalties of up to Rs 250 crore for failure to take reasonable security steps. For your compliance team, this means the cost of avoiding the 160 series migration is not one penalty. It is potentially three separate regulatory actions running at the same time.

How FreJun Supports Your 160 Series Migration

Overall, FreJun is a cloud telephony platform built for regulated entities working through India’s voice-call compliance rules. Consequently, the platform covers the technical migration layer so your legal and compliance team focuses on substantive obligations, not infrastructure setup.

What FreJun Covers in the 160 Series Migration Process

• TSP coordination: FreJun works with licensed TSPs to help eligible BFSI entities get their 1600/1601 number, including preparing and submitting the required undertaking documents.
• DLT template registration: The FreJun team helps prepare, categorise, and submit voice templates to the DLT platform, covering both transactional and service categories.
• Dialer reconfiguration: FreJun configures outbound trunks so service and transactional calls route only through your 1600/1601 number, with automatic caller ID and Template ID passing in call signalling.
• CRM integration: Native integrations with HubSpot, Zoho, Salesforce, and Leadsquared let you log CDRs, track consent status, and enforce calling-hour rules inside your existing workflow.
• CDR and audit trail: Every call gets a full CDR entry with Template ID mapping and consent record linkage, stored on India-based servers consistent with RBI data localisation rules.
• BPO and recovery agent compliance: FreJun’s multi-user setup lets BPO partners place calls through your allocated 1600 number under your PE registration, with separate CDR reporting per agent for audit purposes.

FreJun is not a TSP or telecom operator. Instead, it is the compliance and calling layer between your regulated business and the TSP infrastructure. Every outbound call meets TCCCPR requirements from day one. For broader context on the overall BFSI compliance picture, see FreJun’s BFSI Communication Compliance Guide 2026 and the TCCCPR 2018 Compliance Guide. For a detailed breakdown of both number regimes, see the 160 Series vs 140 Series comparison guide.

Most BFSI teams finish their 160 series migration with FreJun in two to three weeks. See exactly how the platform handles your DLT templates, dialer routing, and CDR logging in a 30-minute walkthrough built around your specific call use-cases.

Talk to FreJun’s Legal Team

Frequently Asked Questions

What is the difference between 160 series and 140 series in India?

The 160 series is for service and transactional voice calls only. Verified Principal Entities hold these numbers, with the 1601 sub-prefix reserved for RBI, SEBI, IRDAI, and PFRDA regulated financial bodies. The 140 series is for promotional and telemarketing calls only. They serve different purposes and cannot replace each other under TCCCPR, 2018 and the Second Amendment dated 12 February 2025.

What is the penalty for missing the 160 series migration deadline?

After the deadline, every service or transactional call from a 10-digit number becomes a violation. Specifically, TRAI classifies it as Unsolicited Commercial Communication from an Unregistered Telemarketer. Financial penalties start at Rs 2,00,000 for the first violation. They rise to Rs 5,00,000 for the second. From the third violation, each instance costs Rs 10,00,000. Additionally, 5 valid complaints in any rolling 10-day period can trigger a one-year blacklist of all telecom resources.

How does a BFSI entity apply for a 1600 series number?

A BFSI entity applies to a licensed TSP with proof of regulatory registration from RBI, SEBI, IRDAI, or PFRDA, plus a corporate undertaking to use the number only for service and transactional calls under TCCCPR, 2018. The TSP checks eligibility before assigning the number. Verify TSP licence status on the SARAL SANCHAR portal at saralsanchar.gov.in before you apply.

How long does the 160 series migration take?

DLT template registration takes two to three weeks for first-time registrants. TSP number allocation takes five to ten business days after you submit complete documents. Dialer and CRM reconfiguration runs in parallel. Most entities finish the full 160 series migration in three to six weeks when they prepare documentation correctly from the start.

Can a recovery agency use its own 10-digit number after the 160 series migration deadline?

No. After the deadline, recovery agencies and BPOs acting for a regulated BFSI entity must use the Principal Entity’s allocated 1600/1601 number. The Principal Entity bears liability for agent calls under TCCCPR and the RBI Fair Practices Code. Any call the agency places from a 10-digit number on the bank’s behalf counts as a violation by the bank.

Does the 160 series migration cover OTP delivery calls?

Yes. OTP delivery calls are transactional calls and must come from a 1600/1601 number after the deadline. Under the TCCCPR Second Amendment dated 12 February 2025, each transactional call must also go out within 30 minutes of the customer-initiated event. OTP calls beyond 30 minutes become service calls and need a different consent basis.

What happens to a bank’s 140 number after the 160 series migration?

The 140 series covers promotional and telemarketing calls only. A bank using a 140 number for service or transactional calls already breaks TCCCPR, 2018, regardless of the 160 series migration deadline. Those calls must move to 1600/1601 at once. The bank can keep the 140 number for promotional campaigns if it runs them, but it cannot use 140 for any service or transactional content.

How does the 160 series migration relate to the DPDP Act 2023?

Every outbound service or transactional call processes personal data. Under Section 7 of the DPDP Act, 2023, your entity as Data Fiduciary must document the lawful basis for that processing. Consent records, opt-out logs, and CDRs from your 1600 number form the evidence base. The Data Protection Board can request this evidence if a complaint arises.

Have more questions about your specific 160 series migration scenario? FreJun’s legal and compliance team has worked through migration cases across banks, NBFCs, insurance companies, and fintechs. Reach out for a clear walkthrough of your entity’s compliance position.

For Any Questions Reach Out to Our Legal Team

Key Takeaways

• The 160 series migration is mandatory for all RBI-, SEBI-, IRDAI-, and PFRDA-regulated entities under the TRAI Direction dated 19 November 2025 (PRID 2191647), with SEBI deadlines already active.
• The five steps of a correct 160 series migration are: eligibility check, TSP allocation, DLT template registration, dialer reconfiguration, and audit trail setup. Each step has specific documentation and sequencing rules.
• Start DLT template registration in parallel with your TSP application. Running both together saves weeks in your total migration timeline.
• Recovery agencies and BPOs must use the Principal Entity’s 1600/1601 number. The Principal Entity bears liability for all agent calls under TCCCPR and the RBI Fair Practices Code.
• The one-year telecom blacklist is the most severe consequence of skipping the 160 series migration. It is operationally worse than any financial penalty.
• Consent records, CDR logs, Template ID maps, and complaint logs must be maintained continuously after go-live as part of your TCCCPR and DPDP Act posture.
• FreJun handles the technical migration layer, from TSP coordination to CRM integration, so your compliance team focuses on substantive regulatory duties.

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, 16 December 2025 (PRID 2205350) – pib.gov.in
• TCCCPR Second Amendment, 12 February 2025 – trai.gov.in (PDF)
• RBI Master Direction on Outsourcing of IT Services, 10 April 2023 – rbi.org.in
• DPDP Act, 2023 – meity.gov.in
• SARAL SANCHAR Portal (TSP Licence Verification) – saralsanchar.gov.in
• TCCCPR 2018 Landing Page – trai.gov.in/tcccpr