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TELECOM REGULATORY AUTHORITY OF INDIA

1-Il«r tHqsl~I Government of India
12th May, 2023

DIRECTION

Subject: Direction under section 13, read with sub clauses (i) and (v) of
clause (b) of sub-section(l) of section 11, of the Telecom Regulatory
Authority or India Act, 1997(24 of 1997) regarding measures to curb
misuse of Headers and Content Templates under Telecom Commercial
Communication Customer Preference Regulation, 2018 (6 of 2018)

F. No. RG-25/(6)/2022-QoS - 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 19th July, 2018 (hereinafter referred to as the "regulations"), to regulate
unsolicited commercial communications;

3. And whereas regulation 17 of the regulations provide that the Authority

may direct Access Providers to make changes, at any time, in CoPs and Access
Providers shall incorporate such changes and submit revised CoPs within
fifteen days from the date of direction issued in this regard;
4. And whereas, 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 TRAIAct and the provisions of the regulations, issued
a Direction No.RG-25j(6)j2022-QoS dated 16th Feb, 2023 to all Access
Providers pertaining to headers and content template, and a copy of the said
direction is enclosed as Annexure to this Direction;

5. And whereas after the issue of the said Direction dated 16th February,
2023, the Authority received representations, not brought to the notice of the
Authority in earlier discussions including discussion in JCOR, from various
Principal Entities and Access Providers, stating, inter alia, that -
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(a) there are quite good number of genuine templates, like templates
for IRCTC Ticketing information, Stock Trading information,
information with respect of sugarcane procurement and settlement,
etc., which require more than three variables and hence limit of upto
three variables in content template is not sufficient to convey the
intended message to the recipients; and

(b) certain variables, such as names, addresses, etc., require more

than thirty characters, as such not allowing two consecutive variables
restricts the completeness of information in respect of name, address,
etc.;

6. And whereas after examination of the aforesaid representations, the

Authority has observed that-

(a) there is a need to review the maximum number of variables

and their placements allowed in a content template; and
(b) at the same time, there is also a requirement to keep a
check on usage of variables so as to ensure that the
intent/information of the original message, for which the content
template was approved, is not changed by the intermediaries;

7. Now, therefore, in continuation of its earlier direction dated 16th

February 2023, 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 ofIndia Act, 1997(24 of
1997) and the provisions of the Telecom Commercial Communications
Customer Preference Regulations, 2018 (6 of 2018) hereby directs all the
Access Providers to-

(a) 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-

(i) after examining the sample message, reasons and

proper justification for more variables shall be recorded by
the competent authority designated by the Access Provider
for this purpose and such authority shall be different from
the authority designated for the approval of content
templates;

(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;

(iii) minimum thirty percent characters in the content

template shall be fixed content;

2
(b) allow, where it is not possible to put the contents of a
variable within the limit of thirty characters, more than one
contiguous variable of the same type, after proper examination
and justifications supported by sample message;

(c) ensure the use of only whitelisted URLsj ApksjOIT linksj call
back numbers in the content template;

(d) ensure that, in case of an URL containing both fixed and

variable parts, the fixed part of URL is whitelisted;

(e) monitor the use of content templates and further, stop any
misuse of special templates; and

(f) update the Code of Practice accordingly within fifteen days

and furnish compliance report of the above direction within forty
five days from date of issue of this direction.

j~\.~ .1~
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(Jaipal Singh Tomar)
Advisor (QoS-II)

To

All Access Providers (including BSNL and MTNL)

3
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TELECOM REGULATORY AUTHORITY OF INDIA
1.IT«f ~:HCf)I~/ Government of India

Dated: 16th February, 2023

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
Communication Customer Preference Regulation, 2018 (6 of 2018).

F. No. RG-25/ (6)/2022-QoS - 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 "TRAIAct"), 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
19th July, 2018 (hereinafter referred to as the "regulations"), to regulate
unsolicited commercial communications;
3. And whereas regulation 3 of the regulations provides that every Access
Provider shall ensure that any commercial communication using its network
only takes place using registered headers assigned to the sender for the purpose
of commercial communication;
4. And whereas regulation 5 of the regulations, inter alia, provides that
every Access Provider shall develop or cause to develop an ecosystem to regulate
the delivery of the commercial communications as provided for in the
regulations and to comply with any other directions, guidelines and instructions
issued by the Authority in this regard;
5. And whereas regulation 8 of the regulations, inter alia, provides that every
Access Provider shall, before allowing any commercial communication through
its network, develop Codes of Practice (hereinafter referred to as "CoPs"] for

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Entities of ecosystem (CoP- Entities) as per Schedule-I and develop CoP for
Unsolicited Commercial Communications Detection (CoP-UCC__ Detect) as per
Schedule-IV, register entities as provided for in the CoP for Entities and register
Senders and assign the headers/ header roots;
6. And whereas sub-regulation (3) of regulation 12 of the regulations
provides that Access Providers shall deploy, maintain and operate a system, by
themselves or through delegation, to register persons, business entities Orlegal
entities in making Commercial Communication through its network involved
from origination, transmission or delivery and have adequate documentary
evidence in support to provide their identities;
7. And whereas item 4 (1) of Schedule I to the regulations provides that every
Access Provider shall carry out Header Registration functions as provided in the
regulations and the relevant provisions of the said item reads as under-

«4. Every Access Provider shall carry out following functions: -

1. Header Registration Function (HRF)

(b) carry out pre-verifications of documents and

credentials submitted by an individual, business entity
or legal entity requesting for assigning of the header;

(c) bind with a mobile device and mobile numberis], in

a secure and safe manner, which shall be used
su bsequently on regular intervals for loqins to the
sessions by the header assignee;

(f) carry out additional checks for look-alike headers

which may mislead to a common recipient of commercial
communication, it may also include proximity checks,
similarity after substring swaps specifically in case of
government entities, corporate(s), well-known brands
while assigning headers irrespective of current
assignments of sucti headers, and to follow specific
directions, orders or instructions, if any, issued from time
to time by the Authority;"
-3-

8. And whereas item 4 (3)of Schedule I to the regulations provides that every
Access Provider shall carry out Content Template Registration functions as
provided in the regulations and the relevant provisions of the said item reads as
under-
«4. Every Access Provider shall carry out following functions: -

(3) Content Template Registration Function (CTRF)

(a) to check content of the template being offered for
registration as a transactional template and service
message template,'
(b) to identify fixed and variable portion(s) of the
content in the offered transactional template and service
message template with identification of type of content
for each portion of variable part of the content, e.g. date
format, numeric format, name of recipient, amount with
currency; reference number, transaction identity;
(c) to estimate the total length of variable portion, viz.
total length of fixed portion for a typical transactional
message, service message for offered template;
(d) to de-register template or temporarily
suspend use of template;

(J) to check content of the template being offered for

registration as a promotional from perspective of content
category)' .... )J

9. And whereas item 5 (lHc) of Schedule I to the regulations provides that

every Access Provider shall set up functional entities like Header Registrar for
keeping record of headers throughout its lifecycle, i.e. free for assignment,
assigned to an entity, withdrawn, surrendered, re-assigned etc.;
10. And whereas item 2 of Schedule VI to the regulations, inter alia, provides
that in preparation of migration plan, the Access Provider shall stop assigning
headers without verification of identity and scope of senders and they shall
register the existing assignee of headers after verification of identity and scope
documents of Unsolicited Commercial Communications senders;
-4-

11. And whereas, the Authority has noticed that-

(a) Headers and Content templates of Principal Entities (hereinafter

referred to as (PEs") are being misused by some telemarketers due to
failure of authentication of data of PEs and there is an urgent need to re-
verify the authenticity of all headers and templates approved on
Distributed Ledger Technologies (hereinafter referred to as "DLT")platform
and cleanse the data within a definite time frame, and that the process of
cleansing DLT data requires periodical actions by the Access Providers;

(b) look-alike headers are being registered by Access Providers on names

of different Principal Entities and many times, such headers create
confusion among recipients of message or even misused by some entities
for their benefit; and

(c) the number of variables in a template is not defined in CoPs which

leads to misuse of the same and moreover, the promotional content is
being passed in the variable portions of content templates and therefore, in
order to minimize the said misuse, number of variables allowed in content
template needs to be limited in a way that not only gives PEs enough
flexibility to phrase their content but at the same time, there are
reasonable restrictions on number and placement of variables;

12. And whereas regulation 17 of the regulations provides that Authority may
direct Access Providers to make changes, at any time, in the CoPs and Access
Providers shall incorporate such changes and submit revised Col-s within fifteen
days from the date of direction issued in this regard;

13. And whereas regulation 18 of the regulations provides that every Access
Provider shall comply with submitted CoPs provided that any provision in CoP
shall not have effect to the extent of being inconsistent with these regulations;
14. And whereas regulation 19 of the regulations provides that the Authority
reserves the right to formulate a standard CoP in case the formulated CoP is
deficient to serve the purposes of these regulations:

15. And whereas regulation 20 of the regulations provides that every access
provider shall comply with the provisions of Standard CoPs;

16. And whereas the Authority is of the view that the above mentioned
provisions of the regulations pertaining to Headers and Content Templates are
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not strictly being followed, and that there is a need to make changes in the CoPs
so as to curb the misuse of Headers and Content Templates;

17. 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 hereby directs all the Access Providers to:

(a) Ensure re-verification of all Headers registered on DLT platform

within thirty days from the date of issue of this direction and blocking of
unverified headers;

(b) ensure to develop, within sixty days from issue of the direction, a
system to-
(i) temporarily deactivate all headers which remain unused
in last thirty days;

(Ul reactivate headers by PEs through an online process; and

(iii] ensure that PE shall classify every header at the time of
registration as 'temporary' or 'permanent' header, as the case may
be, and that the 'temporary' header shall be deactivated after the
time duration for which such 'temporary' header has been
registered;
(c)ensure that each Header is distinct and shall reject, during registration,
such Headers which are similar by virtue of combination of small case or
large case letters;
(d) ensure re-verification of all content templates within sixty days of
issue of this direction and blocking of unverified templates;
(e) incorporate procedure for quarterly re-verification of Headers and
content templates in their respective CoPs;
(f) 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
(g) ensure that variables in the content templates are non-contiguous
and not separated with space, comma and/or any other special
characters.
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18. All the Telecom Service Providers are di.rected to comply with the above
directions and forward updated status on actions taken, including updating of
CoPs, within thirty days from date of issue of this direction.

r~ r~ ; ~~. 6 ! r \) '2 I 4-' rL

-(Jalpal Singh Tomar)
.~

Advisor (QoS)
To
All Access Providers (including BSNL and MTNL)