AI calling compliance in India.
Legal, within the TRAI, DPDP and RBI rules.

Is AI calling legal in India? The short answer

Yes. A business can call customers with an AI voice agent in India, as long as the calls follow the rules every commercial call follows, plus one added in 2026. Under TRAI's amendment of 18 September 2026, calls placed by software count as A2P (application-to-person) calls, and A2P calling has to be declared to the telecom operator before it starts.

In six lines:

• Declare it. The operator has to know in advance that automated calls are coming, and from which caller IDs. TRAI treats A2P calls that weren't declared as spam. On the numbers Kallix provides, Kallix makes this declaration through Vobiz.
• Pick the right numbers. The 140 series is for promotional calls. The 1600 and 1601 series are for service and transactional calls. Kallix provides 140-series and regional numbers through Vobiz, and helps you get 1600 and 1601-series numbers issued in your business's name.
• Respect DND. A promotional call needs the person's DND preference or their registered consent on its side.
• Hold consent. Under the DPDP Act you need a lawful basis, usually consent, to call people and to record the call.
• Lenders: 8 am to 7 pm. RBI bars recovery calls to borrowers outside those hours.
• Say it's an AI. No Indian rule requires it on calls yet. Every Kallix agent does it anyway, in its first line.

Which rules apply to an AI call

TRAI rules for AI calls: what changed in 2026

TRAI's Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) govern commercial calls and SMS in India. TRAI published a draft Third Amendment for consultation on 13 March 2026, held an open house on 3 June 2026 and introduced the amendment on 18 September 2026. Four parts of it matter if an AI agent makes your calls.

AI calls are A2P calls, and they're declared

TRAI defines an A2P call as a voice call started by an application, software or automated platform, with no person dialling. Autodialled calls and calls in a pre-recorded or artificial voice are included, so an AI voice agent is covered.

• Declaration. Before the first call, every business that makes A2P calls tells its telecom operator so, and lists the caller IDs (CLIs) it will call from.
• If nobody declares. TRAI treats undeclared A2P traffic as unsolicited commercial communication (UCC), the regulation's word for spam.
• Termination charge. Operators may charge each other up to ₹0.05 a minute to carry A2P calls. Calls from the series set aside for regulated commercial calls don't pay it.
• Start dates. TRAI's release doesn't give them. Check the gazette text, or ask your operator, before you plan a launch around a date.

The 140, 1600 and 1601 number series

• 140: promotional calls.
• 1600 and 1601: service and transactional calls.
• Not marked as spam. Calls from these series must not be shown to people as spam. Caller-ID and spam-blocking apps may not block or spam-tag them wholesale, though anyone can still block a number on their own phone.
• Ordinary numbers. Since TRAI's February 2025 amendment, telemarketing from ordinary 10-digit numbers isn't allowed.
• Banks, financial services and insurers. A TRAI direction of 19 November 2025 puts their service and transactional calls on 1600 numbers and their promotional calls on 140 numbers. TRAI is bringing in the 1600 series sector by sector, so check with your operator which date applies to you.

DND and the NCPR

The National Customer Preference Register (NCPR) is the list most people call DND. A person can block every commercial call, or only some categories. A promotional call has to fit the person's preferences, or rest on consent they've registered. People complain about unwanted calls by calling or texting 1909, or through the TRAI DND app.

Spam flags, complaints and consent

• Operators flag spam with AI. Under Regulation 21A, operators use AI and machine learning to spot likely spam callers, and share those flags with each other.
• Flagged caller IDs. If five or more of one sender's caller IDs are flagged within 10 days, the operator investigates and acts in steps: KYC re-verification, a bar on outgoing calls, or disconnection.
• Complaints. Under the amendment, three unique complaints in 10 days trigger action when the operator's AI system has flagged the sender too. The old threshold was five. People complain through the TRAI DND app, their operator's app or 1909, and can appeal a decision within 15 days.
• Calls after an enquiry. When someone asks about your product or service, you may send them commercial communications for seven days. The enquiry has to be in writing or digital, and you keep it in a form that can be checked.
• Older consents. They count only if you took them in a way that can be verified and they're registered on the operators' digital consent platform (DLT).

The full rule-by-rule guide: TRAI rules for AI calls →

DPDP Act and AI calling: consent and dates

The Digital Personal Data Protection Act, 2023 covers how businesses handle people's personal data. Calling someone, recording the call and keeping a transcript all use their personal data, so the Act applies to AI calling. The DPDP Rules, 2025 bring its duties in over 18 months.

What it means on a call:

• A lawful basis. You need one, usually consent, to call a person and to record and process the call.
• A clear notice. People are entitled to know what you collect and what you'll use it for.
• Withdrawal as easy as consent. If a person can say yes in one step, they can say no in one step. Treat "please don't call me again" on a call as exactly that.
• Start now. May 2027 is the date the core duties apply, but the consent you collect this year is the consent you'll rely on then.

On our side, your business is the data fiduciary and Kallix is your data processor, working on your instructions. Call data is stored and processed in India, you choose how long recordings and transcripts are kept, and a data processing agreement is available on request. Kallix is DPDP Act compliant.

More on consent, notices and recordings: The DPDP Act and AI calls →

RBI rules for collection calls: 8 am to 7 pm

RBI's circular on recovery agents (RBI/2022-23/108, 12 August 2022) says lenders and their recovery agents must not call borrowers before 8 am or after 7 pm. RBI's fair-practices rules also forbid harassment and threats.

If an AI agent makes your collection calls:

• Set the window. Keep collection campaigns inside 8 am to 7 pm IST. Kallix campaigns dial only inside the hours you set.
• Cap the calls per borrower. A per-person call limit in Kallix counts every call to that person across all your agents and campaigns, retries included.
• Keep the script factual. The amount, the due date and the ways to pay. No pressure and no threats.
• Never ask for payment details. Kallix agents don't ask for card numbers, OTPs, PINs or passwords. They send a payment link for that account, such as a UPI link, on WhatsApp.
• Record what happened. Kallix logs each call with an outcome such as promise to pay, dispute or already paid, so your team follows up on facts.
• Offer a person. A borrower who wants to talk to your team can be handed over.

How it works on a real campaign: AI debt collection calls →

AI disclosure: our rule, not TRAI's

Every Kallix agent says it's an AI assistant in its first line. That's Kallix policy.

TRAI's release of 18 September 2026 doesn't require an AI call to announce itself. The duty it adds is the declaration to the operator. As of 23 October 2026, no Indian rule requires an AI call to say it's an AI. We disclose anyway, because people deserve to know who they're talking to, and a caller who knows it's an AI can ask for a person straight away. Agents offer one on request.

It's also what RBI's FREE-AI framework recommends. The committee report of 13 August 2025 suggests that banks and other regulated entities tell customers when they use AI, and let them contest decisions an AI makes. That's a recommendation, not a rule. Our first line covers the disclosure part on every call.

An opening line looks like this:

Agent: Namaste, main Asha hoon, Northwind Finance ki AI assistant. Yeh call record ho rahi hai. Aapke EMI ke baare mein call kiya hai. Kya abhi do minute baat ho sakti hai?

The first line can also say the call is recorded. Insurers need that: IRDAI's distance marketing guidelines (2011) require telemarketing calls to be recorded and kept, and the customer told that the call is recorded.

A note on the IT Rules: MeitY's 2026 amendment on synthetically generated content asks platforms to label AI-made content, including audio, that they publish. It's aimed at platforms, not phone calls.

How Kallix helps with AI calling compliance in India

Kallix follows TRAI's rules for commercial calls and is DPDP Act compliant. These are the controls behind that:

• AI disclosure in the first line. Every agent says it's an AI assistant as the call opens, and offers a person on request.
• Numbers for each call type. Through our telephony partner, Vobiz, Kallix provides regional numbers for inbound lines and 140-series numbers for promotions, and helps you get 1600 and 1601-series numbers, issued in your business's name, for the sectors whose service and transactional calls must use them. Inbound and numbers →
• A2P declared for you. Kallix declares automated calling for the numbers it provides through Vobiz, so you don't file that declaration yourself.
• DND checks before dialling. Every number is checked against the NCPR before a campaign dials. On promotional calls, DND-registered numbers are skipped unless the contact carries a consent record.
• Consent kept on the contact. Store each person's consent source and date when you upload a list or push contacts by API.
• Calling windows in IST. Campaigns call only inside the hours you set, with gaps between retries. For collection calls, set them to RBI's 8 am to 7 pm. Campaigns →
• A limit on calls per person. Set the most calls one person can get, counted across every agent and campaign, retries included. An agent can have a tighter limit of its own.
• Do-not-call honoured everywhere. If a person tells the agent to stop calling, it agrees, the call is logged as "do not call", and that contact is left out of every campaign. Send the outcome to your CRM through webhooks or the API.
• Spam-flagged numbers skipped. Caller-number pools skip any number flagged as spam, so campaigns stop dialling from it.
• Numbers whitelisted for you. Kallix whitelists your calling numbers with Truecaller and the telecom operators on your behalf, which helps calls show up as your business rather than an unknown number.
• No payment details on the call. Agents never ask for card numbers, OTPs, PINs or passwords. They send a payment link on WhatsApp instead.
• Call data stored and processed in India. Encrypted in transit and at rest, kept for the periods you choose, and covered by a data processing agreement on request. Security and trust →
• A record of every call. Each call keeps its recording, transcript and outcome, so you can see what was said if a complaint or dispute comes in.

What stays with you as the business

Kallix gives you the controls. Some duties can't move to a platform, because they come from your relationship with your customers.

1. Your DLT registration and your customers' consent. Your business registers on DLT as the sender (the principal entity) and owns the consent to call each person. Keep proof of how and when each person agreed to hear from you. Under TRAI, older consents count only if they're verifiable and registered on the operators' DLT consent platform. Under the DPDP Act, consent comes with a clear notice and must be easy to withdraw. Mark consent on a Kallix contact only when it meets those tests, because it decides whether a DND-registered number gets a promotional call.
2. Enquiry windows. If you call people because they enquired, keep the enquiry in writing or digital form, record it as the contact's consent source and date, and make commercial calls only within seven days of it.
3. The call type and the number. Decide whether each campaign is promotional, service or transactional, keep the script to that purpose, and call from the matching series.
4. Your sector's hours. If you lend, keep recovery calls between 8 am and 7 pm.
5. Your other channels. Kallix leaves do-not-call contacts out of every campaign. Keep your CRM and any other calling teams in step.
6. Your own legal advice. Your sector may add rules this guide doesn't cover.