Description

Direction issued by TRAI on November 18, 2025 under section 13 of the TRAI Act, 1997 regarding measures to prevent misuse of headers and content templates in commercial communications.

Summary

The Telecom Regulatory Authority of India (TRAI) issued a Direction on November 18, 2025 under section 13 of the TRAI Act, 1997 to curb misuse of headers and content templates under the Telecom Commercial Communications Customer Preference Regulations, 2018. This direction mandates Access Providers to implement stricter controls on variable portions in content templates, ensure proper pre-tagging of variables, and allow only whitelisted URLs/APKs/OTT Links/Callback numbers to prevent spam and unauthorized commercial communications.

Key Points

  • Direction issued under section 13, read with sub clauses (i) and (v) of clause (b) of sub-section (1) of section 11 of the TRAI Act, 1997
  • Applies to Telecom Commercial Communications Customer Preference Regulations, 2018 (6 of 2018)
  • Access Providers must limit variables in content templates to two, with third variable allowed only in case of exigency with recorded reasons
  • Variables in content templates must be non-contiguous and not separated with space, comma or special characters
  • More than three variables allowed only in special circumstances with proper justification from Principal Entity
  • Each variable must be pre-tagged for its intended purpose to prevent misuse
  • Only whitelisted URLs/APKs/OTT Links/Callback numbers permitted in content templates
  • Access Providers must update Code of Practice within fifteen days of direction

Regulatory Changes

This direction updates and reinforces previous TRAI directions dated February 16, 2023 and May 12, 2023 regarding content template regulation. The key regulatory changes include:

  • Stricter enforcement of variable limitations in message templates
  • Mandatory pre-tagging of variables for specific purposes
  • Enhanced whitelisting requirements for URLs and links in commercial messages
  • Updated Content Template Registration Function (CTRF) requirements under Schedule-I of the regulations
  • Authority retains power to direct changes in Code of Practice at any time per regulation 17

Compliance Requirements

For Access Providers:

  • Ensure content templates contain maximum two variables; third variable only with documented exigency
  • Verify variables are non-contiguous and properly separated
  • Implement pre-tagging system for variables when more than three are approved
  • Maintain whitelist of approved URLs/APKs/OTT Links/Callback numbers
  • Update Code of Practice within fifteen days from direction date
  • Submit revised CoPs incorporating mandated changes
  • Furnish compliance report within forty-five days (based on previous direction timeline)

For Principal Entities:

  • Submit requisition with proper justification and reasons when requesting more than three variables
  • Ensure variables used only for pre-tagged purposes
  • Comply with whitelisting requirements for all links and callback numbers

Important Dates

  • Direction Date: November 18, 2025
  • BSE Circular Date: November 24, 2025
  • Code of Practice Update Deadline: Within 15 days from direction issuance (approximately December 3, 2025)
  • Compliance Report Submission: Typically within 45 days from direction date (approximately January 2, 2026, based on previous direction patterns)

Impact Assessment

Telecom Sector Impact: This direction significantly impacts telecom operators (Access Providers) and businesses using commercial SMS services (Principal Entities). Companies relying on variable-heavy message templates for customer communications will need to restructure their messaging systems to comply with the two-variable limit or seek special approval with documented justification.

Operational Impact: Access Providers must upgrade their Content Template Registration Function (CTRF) systems to enforce pre-tagging and whitelisting requirements. This may require substantial technical modifications to existing platforms within the tight fifteen-day compliance window.

Consumer Protection: The measures strengthen protection against spam and fraudulent commercial communications by preventing template misuse and ensuring only verified URLs/links are used in bulk messaging, reducing phishing and fraud risks.

Compliance Burden: Increased compliance requirements for both Access Providers and Principal Entities, particularly for businesses requiring complex message templates with multiple variables, who must now provide detailed justifications for approval.

Impact Justification

High severity regulatory direction from TRAI affecting all Access Providers and Principal Entities in telecom sector regarding commercial communications compliance. Requires immediate adherence to prevent misuse of messaging templates.