Direction regarding measures to curb misuse of Headers and Content Templates under Telecom Commercial Communications Customer Preference Regulations, 2018

11Iç'il1 I# UI TE LECOM REGULATORY AUTHORITY OF INDIA ww _iic1 *icDi< / _Government o_f Indi a TRAI November 18, 2025 DIRECTION Subject: Direction under section 13, read with sub clauses (i) and (v) of clause (b) of sub- section (1) of section 11, of the Telecom Regulatory Authority of India Act, 1997 (24 of 1997) regarding measures to curb misuse of Headers and Content Templates under Telecom Commercial Communications Customer Preference Regulations, 2018 (6 of 2018) F.No. D-2711/(2)/2024-QoS (E-13563) Whereas the Telecom Regulatory Authority of India - (hereinafter referred as the "Authority"), established under sub-section (1) of section 3 of the Telecom Regulatory Authority of India Act, 1997 (24 of 1997) (hereinafter referred to as "TRAI Act"), has been entrusted with discharge of certain functions, inter alia, to regulate the telecommunication services; ensure technical compatibility and effective inter-connection between different service providers; lay-down the standards of quality of service to be provided by the service providers and ensure the quality of service and conduct the periodical survey of such services provided by the service providers so as to protect the interest of the consumers of telecommunication service; 2. And whereas the Authority, in exercise of the powers conferred upon it under section 36, read with sub-clause (v) of clause (b) and clause (c) of sub-section (1) of section 11, of the TRAI Act, made the Telecom Commercial Communications Customer Preference Regulations, 2018 (6 of 2018) dated the l9t1 July, 2018 (hereinafter referred to as the "regulations"), to regulate unsolicited commercial communications; 3. And whereas regulation 17 of the regulations provides that the Authority may direct Access Providers to make changes, at any time, in the Code of Practice (hereinafter referred to as "CoPs") and Access Providers shall incorporate such changes and submit revised CoPs within fifteen days from the date of direction issued in this regard; Page 1 of 4 ('lf '1ucIc T), 'Ii R, 9 1a-11O029 , World Trade Center, Tower-F, (4th to 7th Floor), Nauroji Nagar, New Delhi-110029 Tel. : 011-26769600 / wwwtra1.gov.in4. And whereas the Authority, vide Direction No. RG-25/(6)I2022-QoS dated February, 2023, directed the Access Providers to, inter alia, ensure to limit the number of variable portions in content template of messages to two variables only provided that, for the reasons to be recorded, a third variable may be allowed in case of exigency; and ensure that variables in the content templates are non-contiguous and not separated with space, comma andlor any other special characters; 5. And whereas the Authority, vide Direction No. RG-25/(6)I2022-QoS dated l2' May, 2023, in continuation of the direction dated l6' February 2023, referred to in para 4 above, directed all the Access Providers to, inter alia, allow, in special circumstances and on requisition with reasons and proper justification from Principal Entity, more than three variables in the content templates, with the condition that each variable in the message template should be pre-tagged for the purpose it is proposed to be used and no information other than that defined in the pre-tagging shall be included in such variables so as to prevent misuse of the content template; ensure use of only whitelisted URLs/APKs/OTT Links/Callback numbers in the content template; and update the Code of Practice accordingly within fifteen days and furnish compliance report of the direction within forty five days from date of issue of the said direction; 6. And whereas item 4 of Schedule-I of the regulations, inter alia, provides as under:- "4. Every Access Provider shall carry out following functions.- (3) Content Template Registration Function (CTRF) 0) allow, in special circumstances and on requisition with reasons and proper just ifi cation from Principal Entity, more than three variables in the Content Templates, with the condition that (ii) each variable in the message template should be pre-tagged for the purpose it is proposed to be used and no information other than those defined in pre-tagging shall be included in the variables; "; 7. And whereas the Authority has observed that - (a) the directions referred to in para 4 and 5 above have not been implemented till date; and (b) in order to ensure implementation of pre-tagging of variables, various meetings were held with all Access Providers and, vide letter dt 05th September 2025, Cellular Operators Association of India (COAl) proposed various tags for Content Page2of4Templates, which was agreed to by all Access Providers, including MIs BSNL, in the meeting held on 17th September 2025; 8. Now, therefore, the Authority, in exercise of the powers conferred upon it under section 13, read with sub-clauses (i) and (v) of clause (b) of sub-section (1) of section 11, of the Telecom Regulatory Authority of India Act, 1997 (24 of 1997) and the provisions of the Telecom Commercial Communications Customer Preference Regulations, 2018 (6 of 2018), hereby directs all Access Providers to ensure that-. (a) Each variable field in every SMS content template shall be pre-tagged with descriptive labels specif'ing the content type, purpose, and validation criteria, as per Aimexure-I attached herewith; (b) scrubbing and validation of the tagged variable fields against the pre-whitelist of URLs, OTT links, APK links, and callback numbers within thirty (30) days from the issuance of this Direction; (c) all new SMS content templates registered after ten (10) days from the date of issue of this Direction shall be registered only after verif'ing compliance with clause (a) above; (d) remaining content templates shall also be modified to comply with clause (a) above within sixty (60) days from the start of variable tag scrubbing; (e) During the initial sixty (60) days from the commencement of variable tag scrubbing, messages may be processed in a logger mode, i.e. messages shall continue to be delivered after generating the relevant fault messages, even if variable tag validation fails. After expiry of this sixty(60) days period, any message failing variable tag validation shall be rejected outright and not delivered.; (f) Access Providers shall identify Principal Entities associated with fault messages and intimate them of corrective actions required and consequences of continued non- compliance. 9. All Access Providers are directed to comply with the above directions and furnish to the Authority periodical status reports on the progress, every fifteen days, from the date of issue of this Direction. The updated CoP maybe submitted within ninety days from issuance of this Direction. (Deepak Sharma) Advisor (QoS-Il) To All Access Providers Page 3 of 4Annexure-I Tags Purpose I Example Validation & Scrubbing _______________________ Rules _______________________ #number# / #numeric# Numeric values. Must be digits only. No - - alphabets or special chars ___________________________ ___________________________ allowed. #url# Web link placeholder e.g. Must be validated with Track order: #url#. registered CTA, under Static or Dynamic or Short URL ______________________ ______________________ #urlott# Web link placeholder e.g. Must be validated with Download App: #url#. registered CTA, under OTT _________________________ _________________________ or APK #cbn# Call-Back number Must be validated with placeholder e.g. Call #cbn# CTAs registered under for support Number (Mobile or _________________________ _________________________ Landline or Toll Free) #email# Email placeholder e.g. Write Must be valid email regex. _________________________ to #email# for help. __________________________ #alphanumeric# Mixed values (ticket IDs, Letters + Numbers allowed - booking IDs) e.g. Booking -Special chars ID: #alphanumeric#. -Length validation required. Not more than 40 Characters will be allowed in scrubbing ________________________ _______________________ Page 4 of 4