Regulatory Compliance Requirement (TRAI Guidelines)
All commercial communications in India are governed by the Telecom Regulatory Authority of India.
Key Concepts
DND
- DND (Do Not Disturb) = Customers who have opted out of promotional communication
Types of Communication
| Type | Purpose | Target Audience | Compliance Requirement |
| Promotional / Telemarketing | To promote products, services, offers, or brand awareness | Customers who have not blocked promotional calls in DND registry | Consent mandatory; |
| Service | To provide information related to an existing service | All existing customers | Inferred: (e.g., post product/service purchase info) – No consent required Explicit: (e.g., ongoing purchase, drop-off etc.) – Consent mandatory Content must be strictly service-related |
| Transactional | To send critical, real-time information within 30 minutes of the transaction | All customers, including DND-registered | High-priority; must not contain promotional material |
Use of Designated Number Series
As per applicable regulations issued by the Telecom Regulatory Authority of India (TRAI), all businesses engaging in outbound calling must adhere to the following guidelines to ensure compliance:
- 140-series numbers must be used for all telemarketing or promotional calls.
- 160-series numbers are designated for transactional or service-related communications.
The use of regular phone numbers for such activities is not permitted and may result in regulatory non-compliance.
Please ensure that the appropriate number series is used based on the nature of the call to remain compliant with regulations.
Usage in Demo vs Production Environments
POC / Sandbox Usage
- The platform is strictly for internal testing purposes.
- No calls should be made to real customers or end users.
- The platform must not be used for production, promotional, marketing, or support activities.
- Please ensure that the numbers being dialed are known/test numbers where the recipients are aware and won’t raise any complaints.
Production Usage
- Once moving to production, IraVoice will handle live calls and real users as per your requirements.
- Approved configurations and integrations may be enabled.
- You are responsible for ensuring that all call recipients have provided the necessary consent.
- If you are using the production setup for running live campaigns, please share the CRM or any relevant screenshots before initiating the calls.
TRAI Regulations for 140-Series Numbers
When creating outbound campaigns, it is important to configure campaign working hours in accordance with TRAI (Telecom Regulatory Authority of India) regulations.
140-series numbers are designated for telemarketing purposes and are governed by strict telecom compliance rules enforced by service providers.
Allowed Calling Hours
| Day | Allowed Time Window |
|---|---|
| Monday – Saturday | 10:00 AM to 7:00 PM |
| Sunday | Outbound calling not allowed |
- Inbound calling is not supported on 140-series numbers.
- Calls attempted outside the permitted time window may be rejected by telecom providers or result in service errors.
- These restrictions are enforced by telecom operators to ensure compliance with TRAI regulations.
It is recommended to configure campaign working hours accordingly to avoid call failures and regulatory violations.
Pre-Go-Live Validation
Before initiating production campaigns, customers are required to share:
- Sample consent proofs from the CRM system demonstrating that end users have explicitly opted in to receive outbound calls.
- The snapshot containing Company URL/Logo same page.
- Date/Timestamp of the customer opting in.
- Customer phone number and details.
Our team needs to verify that these samples contain the required customer information (like name, phone number, date, etc), which we must be able to share with the SIP trunk provider whenever we receive a complaint.
This is necessary to validate readiness and ensure compliance alignment.
Audit and Complaint Handling
In the event of a complaint, consent records may need to be shared with the SIP trunk provider or relevant authorities.
Steps to Take If You Receive an Audit Notice
When Epicode notifies you of a call audit, follow these steps:
- Verify the audit details:
Epicode will provide the details of numbers to which the complaints have been recieved
- Your Epicode number (caller)
- Recipient’s phone number (callee)
- Call Date & Time
- Complaint Date & Time
- Collect consent evidence: Provide documentation showing the recipient explicitly agreed to receive calls from your organization. The consent evidence must have been obtained within the last six months.
- Submit the proof within 2 working days: Ensure all required information is included (see “Consent Evidence Requirements” below).
- Remove the recipient from your calling list: Prevent repeat complaints by ensuring the number is not called again.
Important: Using a different Epicode number to contact the same recipient may be treated as a compliance violation and could disrupt your service.
Consent Evidence Requirements
Your documentation must clearly demonstrate the recipient agreed to receive calls. Acceptable evidence includes:
-
Required Elements:
- Company name or logo
- Recipient name
- Recipient phone number
- Date consent was provided
- Purpose of consent (marketing/promotional communication)
- Mode of consent capture (web form / app / SMS / written form)
-
Accepted Formats:
- CRM screenshots displaying the above details
- Signed consent forms
- Digital opt-in records
Note:
- Screenshot must be unedited and authentic.
- Submit clear, high-quality images with all elements clearly visible.
- Excel sheets, PDFs, Word documents, or manually prepared files will not be accepted
Audit Process
- A recipient files a complaint with their telecom provider.
- The telecom provider identifies Epicode as the originating service.
- Epicode’s compliance team identifies the customer responsible.
- The customer submits consent evidence within 2 working days.
- Epicode reviews the evidence and forwards it to the telecom provider.
- The customer is notified once the audit is closed.
Compliance Responsibility
TRAI regulations are strictly enforced. Non-compliance may result in actions including, but not limited to:
- Service restrictions
- Suspension or termination of SIP trunks
Customers are strongly advised to ensure full adherence to all regulatory requirements at all times.
Consequences
- If valid evidence is submitted on time:
- Epicode reviews the submission and may request additional details if needed.
- Once approved, the telecom provider closes the audit, and the customer is notified.
- If evidence is insufficient:
- Epicode will request corrected or additional documentation.
- Failure to respond within 2 days can lead to temporary suspension, permanent account blocking, or escalation to TRAI.
- Multiple complaints:
- Repeated violations may result in blacklisting.
- For resellers, incorrect compliance mapping may result in action on the entire account.
Complaint Mechanism as per Regulation Amendment
If it is found that the number of complaints against the Sender are from five or more unique Recipients during the last ten days, the following actions shall be taken:
- Suspend the outgoing services of all the telecom resources of the Sender that were utilized for sending Unsolicited Commercial Communications (UCC).
- Initiate an investigation by issuing a notice to the Sender under sub-regulation 5(d)(i), providing the Sender an opportunity to represent their case.
- Complete the investigation within five business days from the date of receipt of the Sender's representation.
- Record the reasons for the findings.
If the investigation concludes that the Sender was engaged in sending Unsolicited Commercial Communications (UCC), the following actions shall be taken:
First Instance of Violation
- Outgoing services of all telecom resources of the Sender, including PRI/SIP trunks, shall be barred by all Access Providers for a period of 15 days, irrespective of whether resources other than the misused resource were used for sending UCC.
Second and Subsequent Instances of Violation
-
Disconnection of Telecom Resources
- All telecom resources of the Sender across all Access Providers, including PRI/SIP trunks, shall be disconnected for one year, irrespective of whether resources other than the misused resource were used for sending UCC.
-
Blacklist
- The Originating Access Provider (OAP) shall place the Sender under the blacklist category.
- No new telecom resources shall be provided by any Access Provider to the Sender during this period.
-
Device Blocking
- All devices used for making UCC shall be blocked across all Access Providers for a period of one year.
Proviso: One telephone number may be allowed to be retained by the Sender during this period.
Note: Epicode reserves the right to block traffic, disable numbers, or suspend services in accordance with its Acceptable Use Policy.

