Telecom service providers must ensure that variable content in commercial messages is pre-tagged with descriptive labels, as per the Telecom Regulatory Authority of India’s (TRAI) recent directive. These descriptive labels must specify the content type, purpose, and validation criteria. By validation criteria, TRAI means that if the variable content is a number or numerical value, the telecom operator must verify that it is indeed a number and that no special or alphanumeric characters are included.
In addition, telcos must verify tagged variable fields against a pre-whitelist of URLs, over the top (OTT) links, APK links, and callback numbers within thirty days. All new SMS templates issued by a telco within ten days of the direction must comply with the pre-tagging requirements.
For the first 60 days after the directive, telcos will continue delivering messages even if validation errors occur, but they must record all errors in the background. They will track businesses sending messages with these errors and inform them about corrective measures and the consequences of continued non-compliance. For instance, if a business sends a message with “Rs #number#” but enters “2,500.00” within the first 60 days, the telco will only document the error and inform the business to fix it. After this period, such messages will be blocked.
Why is TRAI mandating tags variable message content?
TRAI explains that investigations into unsolicited commercial communication (UCC) found that bad actors exploit the absence of pre-defined tags for fraudulent and phishing activities. They insert unregistered or malicious URLs, app links, and callback numbers into approved commercial message templates without detection. The regulator said the direction “aims to further strengthen the anti-spam and anti-fraud framework by ensuring complete visibility of variable fields in SMS.”
According to the directive, TRAI held meetings with telecom companies to facilitate the implementation of pre-tagging. On September 5, the Cellular Operators Association of India (COAI) wrote to TRAI proposing various tags for commercial message content templates. All telcos have agreed to these tags.
How do commercial message registrations currently work?
Under the Telecom Commercial Communication Customer Preference Regulation (TCCCPR, 2018), TRAI requires telecom companies to establish a distributed ledger technology (DLT) platform to register companies/telemarketers sending commercial messages. The platform also registers headers and content templates for commercial messages.
Templates fall under three categories: promotional, transactional, and service messages. Businesses must select a message category and a registered SMS header, and then demarcate the fixed and variable parts of the content template.
- The fixed part remains the same across all communications.
- The variable part changes based on the transaction, recipient, date, time, place,…
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