AI voice agents make it easy to call thousands of customers in a day. That is exactly why the rules matter. In India, the rules that apply when someone from your team picks up the phone also apply when an AI agent does the dialling, and a campaign that ignores them can lead to complaints, blocked numbers and penalties.
This is not legal advice. It is a practical overview, written in October 2026. Telecom and data protection rules in India change often, and how they apply depends on your sector and the calls you make. Check the current TRAI directions and speak to your own legal adviser before you launch a campaign.
TRAI's rules on commercial calls
The main regulation is TRAI's Telecom Commercial Communications Customer Preference Regulations, 2018, usually shortened to TCCCPR. It covers commercial SMS and voice calls, and it is enforced through the telecom operators.
DLT registration
Under TCCCPR, businesses that send commercial communication (the regulations call them principal entities) register on Distributed Ledger Technology (DLT) platforms run by the telecom operators. Registration records who you are and which telemarketers act for you, and for SMS it also covers your sender headers and message templates.
The DND register
The National Customer Preference Register (NCPR) is what most people call the DND list. Customers can register by calling or texting 1909, or through TRAI's DND app, and they can block all commercial communication or only some categories, such as real estate or banking products.
Promotional calls must not reach a number that has opted out of that category, unless the customer has given consent in the way TCCCPR requires. That consent is recorded through the operators' systems, so a tick box on your own website may not be enough. DND preferences mainly govern promotional communication. Service and transactional calls are treated differently, but they must genuinely be about something the customer already has with you.
Promotional, service and transactional calls
The regulations treat calls differently depending on their purpose. As a working guide:
| Type | What it's for | Examples |
|---|---|---|
| Promotional | Selling or marketing something new | A loan offer, a new course, a property launch, a festive sale |
| Service | Information about a product or service the customer already has | An order update, an EMI due date, a policy renewal date, an appointment reminder |
| Transactional | Confirming something the customer has just done | A payment received, a booking made |
Watch for calls that drift. A payment reminder that ends with "and would you like a top-up loan?" can be treated as promotional. Keep service calls to the service, and run offers as separate promotional campaigns.
Dedicated number series
TRAI has mandated dedicated number series for commercial voice calls, so customers can tell what kind of call it is before they answer. Numbers starting with 140 are for promotional calls. Banks, financial services firms and insurers use numbers starting with 1600 for service and transactional calls, and since August 2026 courier and logistics firms can get 1601 numbers for theirs. Both are allotted in the business's own name. Promotional calls should not come from ordinary 10-digit mobile numbers. The series, and the sectors they cover, have changed more than once, so check the current TRAI directions before you choose numbers for a campaign.
AI calls since September 2026
On 18 September 2026 TRAI introduced the third amendment to TCCCPR, and it names AI calls directly. A call placed by software, an AI voice agent included, is an A2P (application-to-person) call. A2P calling, and the caller IDs it will use, has to be declared to the telecom operator in advance, and undeclared automated calls are treated as unsolicited commercial communication. Operators also use AI to spot likely spam callers, and fewer complaints are now needed before they act.
The amendment doesn't ban AI calls, and it doesn't require the agent to say it's an AI on the call. For the full picture, read our guide to TRAI rules for AI calls →.
Calling hours
There isn't one rule on calling hours for every business, but there is a clear expectation that you don't call people early in the morning or late at night. For lenders it is written down. RBI's guidance on recovery agents, which sits alongside its fair practices code for banks and other regulated lenders, says borrowers should not be called before 8 am or after 7 pm about overdue loans (RBI circular on recovery agents, August 2022).
Many businesses outside lending use a similar daytime window as good practice, think twice before calling on Sundays and public holidays, and always honour a time the customer asks for. Set the window in the customer's local time: IST for customers in India, and their own time zone for customers abroad.
The Digital Personal Data Protection Act, 2023
The DPDP Act sets out how businesses (data fiduciaries, in the Act's language) may handle personal data, and a phone number, a name and a call recording are all personal data. Its obligations are being brought into force in stages through the DPDP Rules, so check what applies to you today. The parts that matter most for calling:
- Notice: when you ask for consent, tell people clearly what data you collect, why you need it, and how they can withdraw consent or complain.
- Consent: consent should be free, specific, informed and given by a clear action. A pre-ticked box or a line buried in your terms is a weak basis for calling someone.
- Purpose limitation: use the data only for the purpose you gave. A number collected to deliver an order isn't automatically a number you can call to sell insurance.
- Withdrawal: withdrawing consent should be as easy as giving it. If a customer says "don't call me again" on a call, treat it as a withdrawal and act on it.
- Retention and security: keep data only as long as the purpose needs it, protect it while you hold it, and delete it when you are done.
Recording and AI disclosure
Recording calls helps with quality checks and disputes, but a recording is personal data. Good practice is to say early in the call that it is being recorded and to keep recordings only as long as you need them.
Telling people they are speaking to an AI is also good practice, whatever the rules in your sector say today. It is honest, it sets expectations and it gives the customer a clear choice to ask for a person.
A checklist before your first campaign
- Confirm your DLT registration and your telemarketer arrangements.
- Check that your AI calling is declared to the operator as A2P, and who files that declaration.
- Classify the campaign as promotional, service or transactional, and keep the script to that purpose.
- Check where each contact's consent came from, and keep a record of it.
- Scrub promotional lists against DND preferences and your own do-not-call list.
- Set calling hours in the customer's local time.
- Add a disclosure line: who is calling, that it is an AI assistant and that the call is recorded.
- Test that "don't call me again" works, end to end.
How Kallix helps
Kallix can't follow these rules for you, and nothing replaces your own registrations and legal advice. What the platform gives you is a set of controls built to support these rules:
- DND checks: every number is checked against the DND register (NCPR) before a campaign dials it.
- Numbers and A2P: Indian numbers through our telephony partner, Vobiz, with 140-series for promotional calls and 1600 or 1601-series for service calls issued in your business's name. Kallix declares A2P calling for the numbers it provides.
- Calling windows in IST: every campaign has a calling window and gaps between retries, so the agent only dials inside the hours you set.
- Do-not-call handling: when someone asks not to be called again, the agent acknowledges it, ends the call politely and tags the call "do not call", so you can exclude the number from future lists and sync it to your CRM.
- A disclosure line in every agent: agents introduce themselves as AI assistants and offer a person on request. You can add a recording notice to the first message.
- Consent records: store the consent source and date as contact variables when you upload a list or push contacts by API. Every call keeps its recording and transcript, so you have a record of what was said, including the disclosure and any opt-out.
Call data is stored and processed in India. You can read more about how we handle it on our security and trust page →, and see every rule in one place in our AI calling compliance guide →.
Again, this is not legal advice. These rules change often and the details depend on your sector. Treat this guide as a starting point, check the current TRAI, RBI and DPDP requirements, and get advice from your legal adviser before you call customers at scale.
The Kallix team
We build AI voice agents for India’s phone-first businesses. Questions about this post? Write to hello@kallix.in.