New DLT Platform - TRAI Rules 2020 For BULK SMS

Distributed Ledger Technology (DLT) is a block-chain based registration system. It is implemented in the public interest to control the SMS spam. whoever wants to send promotional bulk sms or transactional SMS to their customers needs to be DLT registered.

This is to bring to your notice that Telecom Regulatory Authority of India (TRAI) has released The Telecom Commercial Communications Customer Preference Regulations, 2018 (Regulation) in July 2019 in its continuous endeavour to create a cleaner and transparent system in the India telecom industry and to curb Unsolicited Commercial Communication (UCC) along with enhance mobile subscriber policy. The new regulation can be accessed through https://trai.gov.in/sites/default/files/Direction_15072019_0.pdf

With this communication, we intend to keep you informed about the multiple phases for implementing the above Regulation, which has mandated the use of block chain technology also known as Distributed Ledger Technology (DLT) to implement the solution. All operators have already implemented the DLT system (Block chain technology) and first phase of the regulation is to register all Entity/Enterprise on New platform, which is mandatory.

Headers assigned by the Access Providers to Principal Entities
(Business, legal or Government Entities)

Who is a Principal Entity (PE) ?

A commercial Business (Individual or company) dealing with products and services is considered as a Principal Entity (PE). As per TRAI's Regulation, it is mandatory for every Principal Entity (PE) to register on DLT platform for commercial communication

Classification of Principal Entity (PE) :

1. Government Entity
2. Non-Government Entity
3. Cooperative Society
4. Sole Proprietorship
5. Private Limited Company
6. Public Limited Company
7. Educational Institution
8. Political Party
9. NGO
10. Nationalised Bank
11. Private Bank
12. Life Insurance Company
13. General Insurance Company
14. Partnership firm
15. Trust / Club / Association
16. Family Owned Business
17. Others

Commercial Communications Ecosystem

The roles and responsibilities of the five entities present in the Blockchain are:

• Mobile Subscriber: Mobile subscriber is the customer who will receive the SMS. Mobile subscriber has been given the right to provide consent to receive a promotional text from any business, opt-out from receiving texts at any point of time, set preferences and register complains for receiving unwanted and spam messages.

• Principal Entity: Principal Entity is the company or organisation who is sending SMS to its clients and customers. It can be an individual, sole proprietor, partnership firm, or any private/public or Government company who wishes to send SMS to their respective clients. As per the new TRAI rules, it is mandatory for every entity to register with the Telecom Operators in the DLT platform.

• Telemarketer: Telemarketer means the Bulk SMS Service Provider from which an individual or company purchases Bulk SMS to send to their customers. As per the updated TRAI rules, every telemarketer needs to register on the DLT platform to send messages on behalf of the Principal Entity(businesses).

• Access Provider: Access Providers are the telecom Operators such as Vodafone, Ideal, Airtel, MTNL, BSNL who will be directly connected to TRAI and assist in the regulation process.

• Regulator: TRAI, being the regulator has the role of establishing regulatory compliance by auditing and governing the operations to safeguard customers interest and prevent the occurrence of any fraudulent practices.

Read NOTIFICATION

What has changed in the new updated TRAI regulations for Bulk SMS?

• Entity and Telemarketer Registration: Every Business(Principal Entity) and Bulk SMS Service Provider(Telemarketer) will now have to register with the Telecom Operators to send messages to their clients. Earlier the Bulk SMS Providers were required to register with TRAI and there was no registration for the business firms. But with the updated rules, both the Bulk SMS Service Provider and the companies who want to send SMS to their clients need to register with the Telecom Operators.

• Header and Template Registration: Sender ID will now be known as Headers and every header needs to be approved and registered with the Telecom Operators. Similarly, each SMS or template has to be approved by the telecom operators directly. Bulk SMS Service Providers will no longer control the Sender ID, template approval and every header and template detail will be available on the panel to view.

• Message type: Earlier there were 2 routes for sending SMS - Transaction and Promotional.  In the latest update, 3 routes have been introduced - Transactional, Promotional, Service( Implicit and Explicit). As per the new rules,  Transactional route will be reserved only for the banks for sending OTPs and service related informative messages will come under the Implicit category. If a customer has opted to receive promotional SMS from a particular company then it will be come under the Explicit category. General Promotional SMS including offers, discounts will be delivered only to Non DND numbers.

• Customer consent: The new regulation grants complete control to the mobile subscriber(customer) for managing their consent for receiving messages and also opt-out it at their will. The list of consents which they have given will be made visible on a single dashboard allowing them to manage and even withdraw their consent at any point of time.

• Customer Preferences: Previously, customers only have the choice between DND and Non DND. In the new rules, the customer, also known as the mobile subscriber has been offered a time-window where they can manage their preferences based on a specific time or day and allow certain kind promotional messages regardless of their selected preferences. It means even if a customer has activated DND on his number then also he can receive promotional text from a company if he wish to. Also, customers can allow to receive promotional texts on a particular time of the day.

• Scrubbing function: To ensure that the messages are sent according to the specifications set by the customer, scrubbing function has been introduced. In this, numbers on which messages has to be sent will be filtered in real-time to match the desired criteria set by the customer. It means that if a customer has given consent to receive messages on Monday, but withdraws the permission on Sunday, then the SMS will not be delivered on Monday. Filtration of the customer preferences is done in real-time and the results are immediately visible.

• Complaint Management: To enhance the safety and authenticity in the system, customers are allowed to register complains regarding the violation of their preferences or consent via different mediums like call and SMS.

• Interoperability between telecom service providers: Each Telecom Service Provider will be eligible to view the details such as registration of entity, telemarketer, header, template submitted, etc. on the platform. The information shared by a particular Business and Bulk SMS Service Provider will be made available across the network which can be viewed at any time.

• 100% Traceability: The whole system operates in a Distributed Ledger Technology (DLT). This means that everything is recorded and shared on the network using Blockchain Technology and can be traced back at any given time.

The sole objective of the regulation is to bring transparency in the system and it is expected that with the use of Blockchain-based DLT platform, unsolicited, spam and fraudulent activities can be minimized to a great extent.

We request you to register on the DLT platform as soon as possible to avoid any inconvenience in sending SMS.

Each User, Reseller and SMPP User can register as Enterprise under our Telemarketer ID as below

Once you have registered on any one of the DLT Portal, you have to register your Headers (Sender IDs) in the Operator's DLT Portal. Your SMS will get delivered only with the Headers (Sender IDs) which are approved in the DLT Portal of the Operator.