TCCCPR-Compliant Collection Calling India 2026: The Complete Operations Guide

TCCCPR-compliant collection calling in India is no longer a compliance aspiration. It is a hard operational requirement in 2026. TRAI has mandated phase-wise adoption of 1600-series numbers for all RBI-regulated entities making service and transactional outbound calls. Collections teams at banks, NBFCs, fintechs, and recovery agencies sit at the sharpest end of this mandate. They generate the highest outbound call volumes, use the most third-party agents, and carry the greatest risk of non-compliance. This guide gives collections heads and operations managers every rule, every deadline, and every practical step they need to run a legally compliant calling operation.

Key Facts at a Glance

Item	Detail
Primary regulation	TCCCPR, 2018 (Second Amendment, 12 February 2025)
Governing bodies	TRAI, DoT, RBI, SEBI, IRDAI, PFRDA
Applies to	All banks, NBFCs, HFCs, fintechs, BPOs and recovery agencies acting on their behalf
Required number series	1600-series (sub-prefix 1601 for RBI/SEBI/PFRDA/IRDAI regulated financial entities)
First-violation penalty	Rs 2,00,000 per instance
Blacklist trigger	5 valid complaints in any rolling 10-day window
Maximum blacklist	1 year, all telecom resources, all TSPs
RBI collection call hours	08:00 to 19:00 IST only (outbound)
NBFC deadline (asset size above Rs 5,000 crore)	1 January 2026
NBFC deadline (asset size below Rs 5,000 crore)	1 March 2026
Mutual Funds and AMCs	15 February 2026
Qualified Stockbrokers	15 March 2026

• All RBI-regulated entities must use 1600-series numbers for service and transactional outbound calls. Collections calls fall squarely in this category.
• Recovery agencies and BPOs acting on behalf of a bank or NBFC must dial using that entity’s allocated 1600-series number, not their own pool.
• Every call script, IVR opener, and EMI reminder must be pre-registered as a content template on the TRAI DLT platform before the call is made.
• Outbound collections calls are restricted to 08:00 to 19:00 IST under the RBI Fair Practices Code. Any call outside that window breaches both RBI and TRAI rules.
• Penalties for non-compliance run from Rs 2,00,000 for a first violation to a one-year blacklist of all telecom resources, which effectively shuts down collections entirely.

In this article:

1. Why Do Collections Teams Face the Highest Compliance Risk?
2. What Is TCCCPR-Compliant Collection Calling?
3. How Does the 1600-Series Mandate Apply to Collections?
4. What Are the RBI-Mandated Calling Hours for Collections?
5. What DLT Template Requirements Apply to Collection Calls?
6. What Obligations Apply to Recovery Agents and BPOs?
7. How Do Consent and Opt-Out Rules Affect Collections Calling?
8. What Penalties Apply for Non-Compliant Collections Calling?
9. 2026 Migration Checklist for Collections Teams
10. How FreJun Helps Collections Teams Stay Compliant
11. Frequently Asked Questions
12. Key Takeaways

Quick Answer: TCCCPR-compliant collection calling in India requires banks and NBFCs to use 1600-series numbers for all outbound EMI reminders, OTP delivery, and recovery calls. Every script must be registered on the TRAI DLT platform. Calls must happen only between 08:00 and 19:00 IST. Non-compliance triggers penalties from Rs 2,00,000 per violation up to a one-year telecom blacklist.

Why Do Collections Teams Face the Highest Compliance Risk?

Collections teams carry the highest TCCCPR compliance risk among all outbound calling functions at a BFSI entity. They place the largest volumes of calls, use the most third-party agencies, and communicate with borrowers who are already under financial stress. That combination raises the probability of a TRAI complaint, and the complaint threshold now stands at just 5 valid complaints in any rolling 10-day window.

The Fraud Window That Collections Teams Inherit

The Department of Telecommunications, in its Press Release dated 30 May 2024 (PRID 2022249), explained the core problem precisely. The 140-series had become so saturated with promotional calls that consumers stopped answering. Genuine entities then began using regular 10-digit mobile numbers for service and transactional calls, which created a fraud window. Consequently, consumers could not distinguish a legitimate bank call from a scammer impersonating one. Collections teams inherited this problem directly: their agents dialled from 10-digit numbers that looked identical to fraud calls, so borrowers screened them out.

Moreover, industry reports indicate roughly 147 million spam call complaints were lodged in India in 2024. That scale of consumer resistance has a direct impact on contact rates for collections operations. Therefore, the 1600-series mandate is, in part, a structural fix for a problem that was costing BFSI entities genuine recovery outcomes.

What Is TCCCPR-Compliant Collection Calling?

TCCCPR-compliant collection calling means every outbound call related to loan recovery, EMI reminders, OTP delivery, and account alerts must satisfy the rules set out in the Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR), as significantly amended on 12 February 2025. Compliance covers far more than using the right number series. It also encompasses script registration, consent management, calling hours, caller identity disclosure, and record-keeping.

Service Calls vs Transactional Calls in a Collections Context

The TCCCPR draws a precise line between service calls and transactional calls. Collections teams must understand this distinction because it determines the consent requirement and the timing window for every call they make.

A transactional call carries information essential to the customer and triggers within 30 minutes of a customer-initiated event. An OTP call following a borrower’s self-service login is transactional. However, an outbound EMI reminder that a collections agent initiates does not qualify as transactional in this narrow sense. Instead, it falls into the service call category, which requires the consent stack applicable to service communications under the amended TCCCPR.

A service call, by contrast, is one made with consent or via a registered template to facilitate, complete, or confirm a transaction the recipient has agreed to. It also covers safety or account-related information related to a product the recipient has used. Most outbound collections calls, including EMI reminders, overdue notices, and settlement offers, fall within this category. Specifically, implicit consent tied to the loan agreement covers service calls for the duration of that contractual relationship.

In my practice advising telecom-sector clients, I have seen collections heads surprised to learn that their standard EMI reminder call is a service call, not a transactional one. That classification carries direct compliance consequences your legal team must understand before migrating to 1600-series numbers. FreJun’s team can walk you through the exact call mapping for your portfolio.

Talk to FreJun’s Legal Team

How Does the 1600-Series Mandate Apply to Collections?

The 1600-series mandate applies directly and immediately to collections calling. TRAI’s Direction dated 19 November 2025 (PRID 2191647) converted voluntary adoption into a time-bound requirement for all RBI-regulated, SEBI-regulated, and PFRDA-regulated entities. A parallel Direction dated 16 December 2025 (PRID 2205350) brought IRDAI-regulated insurers within the same framework.

Specifically, any outbound call that a bank, NBFC, HFC, or fintech makes to a borrower for loan recovery, EMI reminders, settlement discussions, or account alerts must originate from a 1600-series number. The sub-prefix 1601 designates financial-sector entities regulated by RBI, SEBI, PFRDA, and IRDAI. After the applicable deadline, calls from virtual numbers, SIP-masked numbers, or standard 10-digit mobile numbers all qualify as non-compliant service calls.

Phase-Wise Deadlines for Collections Operations

The phased rollout sets separate deadlines based on entity type and, for NBFCs, asset size. Collections operations must map every outbound trunk against these specific dates.

Entity Type	Deadline
NBFCs with asset size above Rs 5,000 crore	1 January 2026
Mutual Funds and Asset Management Companies	15 February 2026
NBFCs with asset size below Rs 5,000 crore, Cooperative Banks, Regional Rural Banks	1 March 2026
Qualified Stockbrokers	15 March 2026
IRDAI-regulated insurers	As per TRAI Direction, 16 December 2025 (PRID 2205350)

Note: The asset-size thresholds for NBFCs derive from the RBI’s alignment circular dated 17 January 2025. Collections heads should verify the exact cut-off applicable to their entity against the operative TRAI Direction text and their TSP’s allocation schedule before finalising migration timelines.

What Happens If Collections Continue on 10-Digit Numbers After the Deadline?

After the applicable deadline, TRAI classifies any service or transactional call from a standard 10-digit mobile number as Unsolicited Commercial Communication from an Unregistered Telemarketer (UTM). The enforcement path for a UTM entity moves quickly. First, TRAI issues a warning. Second, a usage cap limits the entity to a maximum of 20 outgoing voice calls per day. Third, TRAI disconnects all telecom resources. For a collections operation, that progression is existential.

What Are the RBI-Mandated Calling Hours for Collections?

The RBI Fair Practices Code restricts all outbound collections and recovery contact to 08:00 to 19:00 IST. This window applies regardless of whether the call originates from an internal collections team or an outsourced recovery agency. Any outbound call placed before 08:00 or after 19:00 directly violates the Fair Practices Code and, additionally, constitutes an independent TCCCPR breach when the call amounts to unsolicited commercial communication outside permitted hours.

Customer-Initiated Contact Outside the Window

The 08:00 to 19:00 restriction covers only outbound calls initiated by the lender or its agents. Customer-initiated contact outside that window remains permitted. However, collections teams should not use a customer’s late-evening call as an opportunity to conduct a substantive recovery discussion that the entity itself could not have initiated. RBI would treat that approach as a constructive violation of the Fair Practices Code, and supervisory attention could follow.

Furthermore, auto-dialers and robo-calls must disclose their automated nature at the start of every call. The TCCCPR Second Amendment, 2025 makes this a mandatory legal requirement, not a best practice. Collections IVR systems must include this disclosure before any customer-facing message plays.

What DLT Template Requirements Apply to Collection Calls?

Every voice script a collections team uses must be pre-registered as a content template on the Distributed Ledger Technology (DLT) platform operated by a TRAI-recognised access provider. This obligation covers every call type in the collections workflow: IVR openers, agent introductions, EMI reminder scripts, OTP delivery messages, overdue balance notifications, settlement offer disclosures, and legal notice follow-up calls.

Step-by-Step DLT Template Registration for Collections

1. Entity registration: The Principal Entity (the bank or NBFC) registers its organisation on the DLT platform, providing regulatory registration details and the name of the sectoral regulator, whether RBI, IRDAI, SEBI, or PFRDA.
2. Header registration: The 1600-series number allocated to the entity becomes its registered header for voice calls. This number must match the caller ID presented during every call.
3. Template creation: Each distinct collections script goes through as a separate template. Variable fields such as borrower name, loan account number, and overdue amount use curly bracket notation.
4. Template approval: The access provider reviews each template for TCCCPR category compliance. Approval typically takes 2 to 3 weeks for first-time registrants.
5. Template ID mapping: The approved Template ID maps into the dialer system. Every outbound call must pass the correct Template ID in the call signalling metadata.
6. Ongoing maintenance: Teams must review templates whenever a script changes. Using a modified script under an old Template ID constitutes a violation.

In practice, the template registration step takes the longest in a collections migration project. Collections operations typically run 10 to 20 distinct scripts across different portfolio segments, and each script needs a separate template. Therefore, collections heads should begin DLT template work at least 4 to 6 weeks before the migration go-live date.

What Obligations Apply to Recovery Agents and BPOs?

Recovery agents and BPOs do not operate under independent TCCCPR obligations when calling on behalf of a bank or NBFC. Instead, they operate under the Principal Entity’s obligations, and that entity carries vicarious liability for everything the agent does.

The Number Allocation Rule for Outsourced Recovery

TRAI allocates the 1600-series number to the Principal Entity, not to the recovery agency. Consequently, recovery agents and BPO call centres must make collections calls using the Principal Entity’s allocated 1600-series numbers. Using their own number pool is non-compliant. This rule is one of the most operationally significant and most frequently misunderstood aspects of the 2026 mandate for collections operations.

The DoT Press Release of 30 May 2024 (PRID 2022249) makes the underlying logic clear: the 1600-series exists so that consumers can identify the calling entity as a verified, regulated institution. When a recovery agency dials from its own number, the consumer-facing benefit of the 1600-series disappears entirely. Moreover, the Principal Entity remains fully responsible for the agent’s conduct under the RBI Master Direction on Outsourcing of Information Technology Services dated 10 April 2023.

IIBF Certification for Recovery Agents

Individual recovery agents must hold a valid certification from the Indian Institute of Banking and Finance (IIBF), obtained after the prescribed 100-hour training programme. The Principal Entity must also maintain a board-approved Code of Conduct for its recovery agents. These requirements sit alongside the TCCCPR obligations, not in substitution of them. Notably, a certified agent calling from an unregistered number or outside permitted hours remains non-compliant.

Additionally, the Principal Entity must inform the borrower when it assigns a recovery agency to the account. This notification requirement, reinforced by the FACE Guidelines on Debt Recovery (August 2025), means that a cold call from a recovery agency with no prior notice raises both a regulatory risk and a complaint risk at the same time.

Conduct Rules Agents Must Follow on Every Call

• Agents must identify themselves and the institution they represent at the start of every call.
• Abusive, threatening, or intimidating language is prohibited under the RBI Fair Practices Code and, in aggravated cases, under the Bharatiya Nyaya Sanhita, 2023.
• Agents cannot discuss a borrower’s default with family members, employers, or third parties. Communication must go only to the borrower or guarantor.
• Agents must maintain records of every call, including the time, number, and outcome. These records form part of the Call Detail Records (CDRs) the Principal Entity must retain.
• Agents must not contact a borrower who has exercised an opt-out for 90 days from that opt-out date, as required by the TCCCPR Second Amendment, 2025.

How Do Consent and Opt-Out Rules Affect Collections Calling?

Consent rules under the TCCCPR Second Amendment, 2025 significantly affect how collections teams may call borrowers. The rules that apply to service calls, which cover most collections activity, break down into three distinct categories.

Implicit Consent for Existing Borrowers

Implicit consent for service calls remains valid for the duration of the underlying loan contract between the NBFC or bank and the borrower. This means collections teams may call an existing borrower about their active loan without separate explicit consent, provided the call originates from a registered 1600-series number, uses a DLT-registered template, and falls within the 08:00 to 19:00 IST window. Once the loan repays or the account closes, the implicit consent lapses. Follow-up calls on a settled account therefore require fresh consent.

The 90-Day Opt-Out Lockout

Once a subscriber opts out of communications for a specific purpose, the entity may not contact them again for that purpose for 90 days from the opt-out date. For collections teams, this creates a genuine operational constraint. A borrower who opts out in the early stage of delinquency remains unreachable by outbound call for three months, even while the account continues to accrue arrears. The Principal Entity must configure its dialer and CRM systems to enforce this restriction automatically, not through manual checks.

Additionally, consent capture must align with the Digital Consent Acquisition (DCA) framework on the DLT platform. Collections teams collecting fresh consent for follow-up communications on settled accounts or prospective borrowers must route that consent through the DCA mechanism. Informal verbal consent during a call does not satisfy this requirement.

The DPDP Act Intersection

The Consent rules under the TCCCPR now intersect directly with Section 7 of the Digital Personal Data Protection Act, 2023 (DPDP Act). Collections calls involve processing a borrower’s personal data, including account number, overdue balance, and contact history. The lawful basis for that processing must be documented. For calls to existing borrowers on active accounts, teams typically rely on a specified legitimate use under the loan agreement. However, collections teams should confirm with their legal counsel that this basis covers every specific processing activity in their workflow, particularly for data shared with outsourced recovery agencies. For more on this topic, see FreJun’s guide to the BFSI communication compliance framework 2026.

What Penalties Apply for Non-Compliant Collections Calling?

The Non-compliant collections calling exposes a BFSI entity to simultaneous penalties from at least three regulatory directions: TRAI, the sectoral regulator (RBI for banks and NBFCs), and the Data Protection Board under the DPDP Act. Crucially, these penalties are not alternative remedies. They stack.

TRAI Financial Disincentives

Under the TCCCPR Second Amendment, 2025, TRAI levies graded financial disincentives per instance of violation on the access provider, and access providers contractually cascade those costs to the Principal Entity. The three tiers are as follows.

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

Blacklisting and Service Disconnection

Financial penalties are serious. However, the service suspension and blacklisting powers are operationally catastrophic for collections. The blacklist trigger now stands at just 5 valid complaints in any rolling 10-day period, reduced from the previous threshold of 10 complaints in 7 days. A collections operation generating that complaint volume, which is not uncommon for a large NBFC running aggressive recovery campaigns, faces a rapid enforcement progression.

For the first violation of the complaint threshold, TRAI bars outgoing services on all telecom resources of the sender for 15 days. For subsequent violations, TRAI disconnects all telecom resources, including PRI trunks, SIP trunks, and 1600-series numbers, across all access providers for one year. TRAI also blacklists the entity on the DLT platform. For a collections operation, a one-year blacklist means OTP delivery stops, customer service calls stop, and all collections outreach stops. The operational cost of that scenario dwarfs any compliance programme budget.

RBI and Sectoral Regulator Penalties

TRAI issued its Direction after Joint Committee of Regulators (JCoR) consultations involving RBI, SEBI, IRDAI, and PFRDA. Non-compliance therefore directly exposes the regulated entity to sectoral regulator action as well. For banks and NBFCs, RBI may take supervisory action under Section 35A of the Banking Regulation Act, 1949, or impose monetary penalties under Sections 46 and 47A. These actions run independently of any TRAI penalty for the same underlying conduct. Additionally, mandatory disclosure of telecom regulatory action in periodic compliance certificates filed with the sectoral regulator adds a reputational dimension that extends well beyond the direct financial cost.

Reading the penalty structure carefully, the combination of TRAI blacklisting and RBI supervisory action for the same non-compliant campaign is not theoretical. The JCoR coordination means both regulators watch the same data. A properly configured 1600-series calling platform costs far less than one enforcement cycle from either regulator. See exactly how FreJun structures compliant collections calling for NBFCs and banks.

Book a Call

2026 Migration Checklist for Collections Teams

The following checklist covers every operational step a collections team must complete to achieve TCCCPR-compliant collection calling. It draws on requirements from the TRAI Direction of 19 November 2025 (PRID 2191647), the DoT Press Release of 30 May 2024 (PRID 2022249), and the TCCCPR Second Amendment of 12 February 2025.

Phase 1: Audit and Inventory

• List every outbound call centre, third-party recovery agency, and automated IVR system the collections function uses.
• Map every outbound trunk and number pool to its current use category: transactional, service, or promotional.
• Identify all trunks currently carrying service or transactional calls that are not yet on 1600-series numbers.
• Confirm the entity’s applicable deadline based on entity type and asset size.
• Review all vendor and BPO contracts to confirm they require use of the Principal Entity’s 1600-series numbers, not the vendor’s own pool.

Phase 2: DLT Registration and Template Preparation

• Register the entity on the DLT platform if not already done.
• Submit the 1600-series number as the registered header for voice calls.
• Create and submit DLT templates for every distinct collections script: EMI reminders, overdue notices, OTP delivery, settlement offer calls, and legal notice follow-up scripts.
• Allow 2 to 3 weeks for template approval by the access provider.
• Map each approved Template ID to the corresponding script in the dialer configuration.
• Archive the original submitted template text and the approval confirmation for audit purposes.

Phase 3: System Configuration and Routing Logic

• Configure the dialer system to enforce 08:00 to 19:00 IST calling hours at the system level, not merely through agent policy.
• Implement technical segregation so that 1600-series trunks cannot carry promotional or marketing calls. This is a routing logic requirement, not a written policy.
• Update IVR scripts to include mandatory auto-dialer disclosure at the start of each call.
• Configure the CRM to flag borrower accounts that have exercised an opt-out and enforce the 90-day lockout automatically.
• Enable CDR capture at the system level to log Template ID, call time, call outcome, and caller ID for every outbound call.

Phase 4: Agent and Vendor Compliance

• Verify that all recovery agents hold valid IIBF certifications obtained after the 100-hour training programme.
• Update the board-approved Code of Conduct for recovery agents to reflect the 2025 TCCCPR amendments.
• Brief all agents on the 08:00 to 19:00 IST calling window and the prohibition on discussing defaults with third parties.
• Issue written instructions to all BPO and recovery agency partners that they must dial using the Principal Entity’s allocated 1600-series numbers.
• Update BPO and vendor contracts to include TCCCPR compliance warranties and audit rights.

Phase 5: Record-Keeping and Ongoing Audit

• Retain full Call Detail Records for the minimum period required by TSP licence conditions and, where longer, by the applicable sectoral regulator’s data retention rules.
• Maintain Template ID logs mapped to each CDR entry.
• Retain consent records where consent formed the basis for the call.
• Retain call recordings where the collections workflow involves recording conversations.
• Maintain complaint logs and resolution trails for every TRAI complaint received through the DND app or 1909 helpline.
• Conduct a quarterly internal compliance review of CDRs to check for after-hours calls, unregistered template use, and opt-out violations.

How FreJun Helps Collections Teams Stay Compliant

FreJun is a cloud telephony and AI-powered calling platform purpose-built for BFSI compliance in India. For collections teams, FreJun handles the technical compliance layer so that legal and operations teams can focus on substantive obligations rather than infrastructure management.

Specifically, FreJun provisions and manages 1600-series numbers for regulated entities, handles DLT template registration and renewal, and enforces calling-hour restrictions at the platform level. It also generates CDRs with full Template ID mapping for every outbound call. Additionally, FreJun integrates directly with HubSpot, Zoho, Salesforce, and LeadSquared, which means collections teams can run compliant outreach from within the CRM systems they already use. The platform also supports routing segregation so that collections traffic and promotional traffic never share the same outbound trunk.

Importantly, FreJun is not a Telecom Service Provider or TSP. It is a cloud telephony platform that works within the TRAI-compliant calling ecosystem. Any entity using FreJun for collections calling should verify, through the SARAL SANCHAR portal, that their chosen TSP holds a valid UL or UL-VNO authorisation, as the Principal Entity’s compliance obligation extends to its vendor chain. For a complete guide to the BFSI compliance framework, see FreJun’s BFSI communication compliance guide 2026 and the TCCCPR 2018 compliance guide.

Collections heads who have already missed their entity’s deadline can still migrate and demonstrate good-faith remediation to TRAI. FreJun can complete the 1600-series provisioning and DLT template registration process in significantly less time than doing it independently. Reach out to understand the exact migration timeline for your portfolio.

For Any Questions Reach Out to Our Legal Team

Frequently Asked Questions

What is the difference between 1600-series and 140-series for collections calls?

The 140-series is exclusively for promotional and telemarketing calls. The 1600-series, specifically the 1601 sub-prefix, is reserved for service and transactional calls made by RBI, SEBI, IRDAI, and PFRDA regulated entities. Collections calls, including EMI reminders and overdue notices, are service calls and must therefore use 1601-series numbers after the entity’s applicable deadline. Using a 140-series number for a collections call constitutes a direct TCCCPR violation.

What penalty applies if a bank continues collections calling from 10-digit numbers after the deadline?

After the deadline, TRAI classifies those calls as Unsolicited Commercial Communication from an Unregistered Telemarketer. Financial penalties start at Rs 2,00,000 for the first instance, rising to Rs 5,00,000 for the second and Rs 10,00,000 per instance for subsequent violations. More critically, 5 valid complaints in any 10-day window can trigger a one-year blacklist across all telecom resources, which shuts down all outbound calling including OTPs.

How does a bank or NBFC apply for a 1600-series number?

The Principal Entity applies through its Telecom Service Provider. The TSP verifies the entity’s eligibility, which requires proof of registration with the applicable sectoral regulator (RBI, SEBI, IRDAI, or PFRDA). Once allocated, the entity must register the number as a header on the TRAI DLT platform and submit all communication templates for approval before making any calls. The entity must also undertake to use the number only for service and transactional calls under TCCCPR, 2018.

Can a recovery agency use its own numbers for collections calls on behalf of a bank?

No. Recovery agencies acting on behalf of a bank or NBFC must use the Principal Entity’s allocated 1600-series numbers, not their own pool. The Principal Entity carries vicarious liability for all agent conduct under the TCCCPR and the RBI Fair Practices Code. A recovery agency dialling from its own number is non-compliant regardless of whether the agency itself holds any separate registrations.

What are the RBI calling hours for collections, and does the TCCCPR impose any additional time restrictions?

The RBI Fair Practices Code restricts all outbound collections and recovery calls to 08:00 to 19:00 IST only. The TCCCPR further empowers TRAI to act against excessive calling through the usage-cap regime, limiting an entity to 20 outgoing calls per day as a penalty measure. Auto-dialers and robo-calls must also disclose their automated nature at the start of every call, as required by the TCCCPR Second Amendment of 12 February 2025.

Does a borrower’s opt-out under TCCCPR stop all collections calls?

A borrower who opts out for a specific communication purpose cannot be contacted for that purpose for 90 days from the opt-out date. However, implicit consent for service calls continues to apply to existing borrowers for the duration of the loan contract. Collections teams must configure their CRM and dialer systems to distinguish between these two states and enforce the opt-out lockout automatically, not through manual checks.

What records must a collections team retain to demonstrate TCCCPR compliance?

The Principal Entity must retain full Call Detail Records with Template ID mapping, consent records where consent formed the lawful basis for a call, call recordings where applicable, and complaint logs with resolution trails. Retention periods follow TSP licence conditions and, where longer, the applicable sectoral regulator’s rules. The DPDP Act, 2023 additionally requires documentation of the lawful processing basis for every category of borrower data used in the collections workflow.

Key Takeaways

• TCCCPR-compliant collection calling requires 1600-series numbers for all outbound service and transactional calls by banks, NBFCs, and their recovery agents. Most large NBFCs crossed their deadline on 1 January 2026. Smaller NBFCs crossed it on 1 March 2026.
• Collections calls are service calls under the TCCCPR. They therefore require DLT-registered templates for every script, including IVR openers, EMI reminders, overdue notices, and settlement offer disclosures.
• Recovery agencies and BPOs must dial using the Principal Entity’s 1600-series numbers. They cannot use their own pool. The Principal Entity is vicariously liable for all agent conduct.
• RBI calling hours restrict outbound collections to 08:00 to 19:00 IST. Auto-dialers must disclose their automated nature at the start of each call. Opt-out borrowers cannot be called for 90 days on the same purpose.
• Penalties stack: TRAI financial disincentives, TRAI blacklisting, RBI supervisory action, and DPDP Act penalties can all apply to the same non-compliant calling campaign simultaneously.
• A one-year TRAI blacklist shuts down all outbound calling, including OTP delivery, which is operationally catastrophic for any BFSI entity regardless of collections volumes.
• FreJun provisions 1600-series numbers, manages DLT template registration, enforces calling-hour controls, and integrates with major CRMs to give collections teams a fully compliant calling infrastructure.

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): DoT allots separate numbering series exclusively for service and transactional voice calls. pib.gov.in
• TRAI Direction, 19 November 2025 (PRID 2191647): Phase-wise adoption of 1600-series by RBI, SEBI and PFRDA regulated entities. pib.gov.in
• TRAI Direction, 16 December 2025 (PRID 2205350): Phase-wise adoption of 1600-series for IRDAI-regulated entities. pib.gov.in
• TCCCPR Second Amendment, 12 February 2025. trai.gov.in (PDF)
• RBI Master Direction on Outsourcing of Information Technology Services, 10 April 2023. rbi.org.in
• DPDP Act, 2023. meity.gov.in
• SARAL SANCHAR Portal for TSP licence verification. saralsanchar.gov.in
• Sigma Chambers analysis: 2025 TCCCPR Amendments. sigmachambers.in
• Vinod Kothari Consultants: Adopting 1600-Number Series, March 2026. vinodkothari.com
• Business Standard: TRAI exclusive numbering mandate raises concern on debt collection, January 2026. business-standard.com