DND registry and AI calling in India: rules, scrubbing and hours.
India's DND system is TRAI's preference register: subscribers block promotional calls by category, mode and time band, or grant registered consent. An AI outbound call must be classed as promotional, service or transactional, scrubbed against those preferences, and, under TRAI's September 2026 amendment, declared to your operator as an A2P call.
Last reviewed 1 October 2026. General information, not legal advice.
What is the DND registry, and what does it actually block?
“DND” is the everyday name for the preference system that TRAI built under the Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR). It replaced the older single National Do Not Call list with a register of preferences. A subscriber can choose to block everything that needs explicit consent (“fully block”), block only promotional communication (“block promo”), or block individual sectors. Preferences are set by calling or texting 1909 or through TRAI's DND app, and they are enforced by the telecom operators, not by the person placing the call. The DND registry glossary entry gives the short definition. The TCCCPR entry covers the regulation itself.
This guide is about the call itself: who you may ring, in what category, when, and what to do with a refusal. It does not repeat how a business registers as a Principal Entity and registers headers and templates; that is covered in TRAI and DLT compliance for AI calling agents and the explainer on DLT registration.
What a subscriber can switch off.
| Option | Effect |
|---|---|
| Fully block (0) | Stops promotional calls and messages and anything that needs explicit consent. Keeps service and transactional communication, and government communication. |
| Block promo (50) | Blocks promotional calls and messages across all categories. Transactional, service and government communication continue. |
| Categories 1 to 8 | Block by sector: banking, insurance, financial products and credit cards; real estate; education; health; consumer goods and automobiles; communication, broadcasting, entertainment and IT; tourism and leisure; food and beverages. |
| Mode and time band | Subscribers can also block by mode (voice or SMS), by time band and by day type. |
Source: Schedule II of the TCCCPR as amended in 2025 and reproduced in TRAI's March 2026 consolidated draft. TRAI can add or remove categories.
Promotional, service, transactional and government calls.
| Class | What it is | Consent and DND | Notes |
|---|---|---|---|
| Promotional | Advertises a product or service. Mixed content makes the whole call promotional. | Only to numbers that have not blocked the category, or with registered explicit consent. TRAI's 2025 explanatory memorandum says autodialled or robo promotional calls should use 140 series numbers. | Opt-out is mandated for promotional messages; offer one on calls too |
| Service | Information on a product or service the person bought: delivery, warranty, recall, security, balance alerts, OTPs. Also calls that facilitate an ongoing transaction. | No explicit consent for information to a customer. Where the call facilitates a transaction, explicit consent is needed and valid for seven days unless revoked. | Reaches blocked numbers; 1600 series intended for automated service calls |
| Transactional | Response to a customer-initiated transaction within thirty minutes: OTP, alert, confirmation, refund information. | No explicit consent. | Treated like service when it carries service information |
| Government | Calls made on the direction of the Central or State Government, constitutional bodies or TRAI, through the DLT platform. | No consent and no opt-out in the register. | Not available to private senders |
Definitions follow the TCCCPR as amended in 2025 and 2026. The 2026 amendment also treats a prior commercial relationship, an inquiry made in writing or digitally in the previous seven days, or an application in the previous three months as a basis for inferred consent.
How does scrubbing work in practice?
Scrubbing means checking a calling list against subscriber preferences and consents before any number is dialled. In the current architecture the check is not a file you download once. The operators run the preference and consent registers on the shared DLT platform and enforce them when a call is placed from your registered header or number series. For you, the practical steps are these.
- Classify the campaign. Decide whether each call is promotional, service or transactional before you build the script. Mixed content is promotional, so a payment reminder that closes with an upsell becomes a promotional call.
- Establish the consent basis. For promotional calls to numbers that have blocked the category, you need explicit consent recorded in the Consent Register. For service calls, the relationship has to be real and the content informational.
- Use the right number resources. The 2025 amendment says commercial communication may only use registered headers or the special number series assigned for it, so a plain ten-digit mobile number is out. Promotional robo and autodialled calls go through 140 series numbers, and service and transactional automated calls through 1600 series. The number series glossary entry and the blog post on 140 vs 160 number series calls go deeper.
- Declare A2P use. Tell your originating access provider in advance that you place A2P calls and which calling-line ranges you use.
- Respect time bands. See the next section.
- Honour refusals in the call and afterwards. If the person says stop, end the call, record the suppression and stop calling. A customer who revokes consent can opt in again, but the sender may re-acquire consent only after ninety days from the revocation.
- Keep records. Keep the consent evidence, the template used and a call log. Complaints are made within seven days of receiving the call, so you need the record quickly.
What are the permitted calling hours?
People often quote 9am to 9pm. The TCCCPR text we reviewed does not set a single national clock. Instead, each subscriber can block time bands: midnight to 6am, 6am to 8am, 8am to 10am, then two-hour bands through to 6pm, 6pm to 9pm, and 9pm to midnight. The Schedule marks the bands from midnight to 10am and from 9pm to midnight as off by default for any subscriber who has set no preference. For a number with no preference registered, 10:00 to 21:00 local time is therefore the defensible default window, and customers who have blocked more bands narrow it. Transactional and service calls are not blocked by time band.
Sector rules can be stricter. Collections, for example, have their own conduct expectations from the regulator, and this guide does not cover them. Confirm the current schedule with TRAI before you fix a window, because TRAI can change the bands.
What are the penalties for ignoring DND?
The regulations work through the network. The access provider is the enforcer, and the financial disincentives written into the TCCCPR fall on access providers that fail to act, not on the sender. For a sender, the consequences are operational and they escalate. Under the 2025 amendment a complaint pattern of five or more unique recipients in ten days can lead to suspension of outgoing services while the case is investigated. A first violation can bar outgoing services across all access providers for fifteen days, and second and later violations can mean disconnection of all telecom resources for one year, blacklisting and blocking of the devices used. Misuse of headers or content templates can bring suspension within six hours and, if a telemarketer is responsible, disconnection for a year.
The September 2026 amendment tightens detection. Operators must use AI/ML systems to flag calling lines with a high probability of sending spam, share the flags through the DLT platform, and act against a sender on three unique complaints in ten days if its line is also flagged. Senders who have five or more flagged lines in ten days face investigation, KYC re-verification and graded action. Consumers also get a fifteen day appeal against the way a complaint was resolved. Parts of the amendment take effect thirty, sixty or ninety days after gazette publication, so check each against your operator.
How do I build a compliant AI outbound workflow?
A workable design separates three questions, and asks them in this order: may this number be called for this purpose, may it be called now, and what happens when the person says no.
- Before the campaign. Register your entity, headers and templates; declare A2P use and calling-line ranges; classify each use case; build the opt-out into the script; agree the disclosure that the caller is an AI.
- At dial time. Check the number against preferences and consent; apply the time band; place the call from the registered series that matches its class.
- During the call. Open with identity and purpose. If the call is promotional, offer the opt-out. If the person asks to stop, comply and log it. Keep promotional content out of service calls.
- After the call. Suppress revoked numbers, hold the ninety-day rule on re-asking, and keep consent and call records. If the call recorded personal data, the DPDP guide to call recording applies as well. TRAI's 2026 text states that nothing in the telecom rules exempts a sender from the DPDP Act.
For examples of calls that fall on the service side, such as order confirmation, see the e-commerce use case. For campaign-level pricing, see pricing.
What Vaami does
Vaami supports TRAI/DLT-registered sender IDs and template scrubbing for outbound campaigns to Indian numbers. DLT registration is completed per customer as part of onboarding, with Vaami's team helping. See the outbound calling product.
What Vaami does not do
Vaami is not a legal adviser or a telecom operator. It does not register your entity for you, decide how your campaign is classified, or take over your consent basis. Those stay with the calling business.
Where this is genuinely ambiguous
- Whether a given AI voice agent is an “A2P” caller. The definition covers calls initiated by software or an automated platform without direct human dialling, which reads broadly, but there is no TRAI guidance specific to conversational AI. Ask your operator.
- Effective dates. The amendment commences in stages from the date of gazette publication. We have not confirmed the exact dates your operator will enforce.
- Borderline classification. A reminder that mentions a new offer, or a feedback call that ends with a pitch, can tip into promotional under the mixed-content rule.
- Calling hours. The time-band mechanism is clear, but a single statutory window is not, so the 10:00 to 21:00 default is our reading of the schedule.
Common questions on DND and AI calling.
Does the DND registry apply to AI voice calls?
Yes, on the plain text of the rules. TRAI's regulations apply to commercial voice calls however they are placed, and TRAI's 18 September 2026 amendment defines Application-to-Person (A2P) calls as calls initiated by software or an automated platform without direct human dialling, including robo-calls and pre-recorded or artificial voice. A promotional AI call may only reach a number whose preference does not block it, or whose owner has given registered explicit consent.
Can I call a number on DND if the customer gave me consent?
Yes, if the consent is explicit consent as TRAI defines it: verified in a robust way and recorded in the Consent Register, or obtained by other verifiable means and then registered there. Promotional calls backed by that consent are delivered irrespective of the customer's preference settings. A verbal yes on an earlier call that you never registered does not meet that test.
What is the difference between promotional, service and transactional calls?
A promotional call advertises a product or service, and if promotional content is mixed into any other commercial call the whole call is treated as promotional. A service call gives a customer information about a product or service they bought, such as a delivery update, warranty or security notice, and needs no explicit consent. A transactional call responds to a customer-initiated transaction, for example an OTP or transaction confirmation. Transactional and service calls can reach a number that has blocked promotions.
What are the calling hours for AI outbound calls in India?
The TCCCPR text we reviewed does not set one national clock. Instead each subscriber can block time bands, and the Schedule marks the bands from midnight to 10am and from 9pm to midnight as off by default for subscribers who set no preference. A cautious default is therefore 10:00 to 21:00 local time. You will often see 9am to 9pm quoted; we did not find that figure in the current schedule. Sector rules, such as those for collections, can be stricter.
What happens if my AI calls get reported as spam?
Under the 2025 amendment, five or more unique complaints in ten days could lead to suspension of outgoing services pending investigation; a first violation can bar outgoing services for fifteen days, and repeat violations can mean disconnection of all telecom resources across operators for a year plus blacklisting. TRAI's September 2026 amendment changes the trigger to three unique complaints in ten days where the calling line is also flagged by the operator's AI/ML detection. Financial disincentives in the regulations fall on access providers, so enforcement reaches you as operator action.
Do I have to declare AI calling to my telecom provider?
From the 2026 amendment, yes for A2P calls. Every sender must declare in advance to its originating access provider that it uses A2P calls, with the calling-line ranges it will use, and the declaration is recorded on the DLT platform. A2P calls made without declaration are treated as unsolicited commercial communication. The provision comes into force sixty days after gazette publication. Whether an AI agent counts as A2P is your counsel's and your operator's call, but the definition is written broadly.
Does Vaami scrub numbers against DND and handle DLT?
Vaami supports TRAI/DLT-registered sender IDs and template scrubbing for outbound campaigns to Indian numbers. DLT registration itself is completed per customer as part of onboarding, because it belongs to the calling business. Vaami is a technology vendor, not a legal adviser, so classifying your campaigns and your consent basis stays with you.
Sources
- TRAI: Telecom Commercial Communications Customer Preference (Third Amendment) Regulations, 2026 (18 Sept 2026) (2026)
- TRAI: Press release on the Third Amendment, 18 September 2026 (2026)
- TRAI: Telecom Commercial Communications Customer Preference (Second Amendment) Regulations, 2025 (12 Feb 2025) (2025)
- TRAI: Consultation on draft Third Amendment, with consolidated TCCCPR schedules (13 Mar 2026) (2026)
- PIB: TRAI strengthens consumer protection with amendments to TCCCPR, 2018 (2025)
Vaami is a technology vendor, not a law firm. This page is general information and not legal advice; regulations change, so confirm current rules with TRAI, your operator and your counsel.
More on compliant AI calling in India.
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