Telecom Regulatory Authority of India (TRAI) in its continuous endeavor to create a cleaner and transparent system in the Indian telecom industry has released a new regulation in July 2018 to curb Unsolicited Commercial Communication (UCC) and enhance mobile subscriber privacy, TCCCPR 18 Telecom Commercial Communications Customer Preference Regulation 2018.
The Regulation is intended to eliminate spam and fraud which has been a concern for many years. The regulation has mandated the use of Blockchain technology also known as Distributed Ledger Technology (DLT) to implement the solution.
To send text messages anywhere within India, one needs to register with the telecom operator as an Enterprise. TRAI has currently directed to stop unregistered entities or enterprises and their header traffic.
To offer regulatory compliant solutions in conjunction with TRAI, to create a much wider and a transparent system, We at Zixflow are taking various corrective measures. Through this guideline, we would like to inform you about the multiple phases for implementation of the regulation.
Steps for DLT registration
Register your business on any operator. You don't have to register on all operators. It will sync with all platforms automatically. Register yourself with a Principal entity or Enterprise. You need to upload KYC documents like Pan Card, GST certification etc. Once you register your company it will generate one request Id. Please keep it for future reference. Now, wait for the approval. It can take 1-7 working days.
Once your business is approved by the operator you will receive the confirmation email by the operator. You will get your unique entity id.
Login to your account and visit the header section on the platform and upload your sender name. It has two dropdowns - Others and Promotional. Select "other" for the transactional message and add sender name with 6 alpha characters. If selected promotional, add a numeric value of six characters. You can add as many as headers you want. Now, wait for the approval. It can take 1-7 working days.
Once the header is approved you will get an email confirmation, Now add the template and upload consent on DLT portal.
Update the Zixflow team via email to add the header name in your account. Once done you can send messages to your customers.
Please note while registering, Select Zixflow Network Pvt Ltd as a telemarketer with telemarketer ID 1102475160000010832 (Unique Registration ID). In any case, if you have done the registration with any other Telemarketer on the operator’s platform already, then you need to update Telemarketer ID.
Operator Wise Guide
Register your business on any one operator. You don't have to register on all operators. It will get sync with all platforms automatically.
DLT Entity Registration Process for PingConnect Videocon:
1. Signup Link: https://pingconnect.in/entity/reg-as
2. KYC Documents for PingConnect: KYC documents like PAN Card, GST, Proof of Identity, Proof of Address etc.
3. Authorization Letter: This is a letter on the company's letterhead, where the Director or Owner of the Company will Authorize the person doing this Registration.
Authorization Letter format can be downloaded from here
In case the Director or Owner himself is doing this Registration, he needs to upload a document that shows he is the Director (MoA or GST)
4. Payment for PingConnect: Just type 00 in the payment option. You don't have to pay anything here.
5. Verification: You will get OTP on Mobile Number and Verification Link on Registered Email Id. Please verify the same. (Check Spam folder as well for email)
6. Login Credentials: Approval will take around 2-3 days and then you will get an Entity Id and Login Credentials on the Registered Email Id by Telecom Operator.
7. Login to DLT Account: Add Header to your account. Follow the below path -
Login into your account >> on left panel >> click on the header >> Click on New Header.
Click On header type and select header: Other >> If you are using our Transactional or SendOTP Routes. Promotional >> If you are using our Promotional Route
Click on Category >> scroll down to select your working category, e.g. Education, Real Estate, Technology, Entertainment etc.
Enter the Header which matches your Company Name or Brand Name (Ex- Zixflow will use Sender as Zixflow) and click on 'check availability'. If not available, try another. (Hint - Add Headers name with only 6 alphabet characters only. It should be alphabet only)
Available Sender Id matches the Company Name, then you will get the OTP, Verify the same. Note - If the Header Name does not match your Company Name, then upload a document to prove that brand name belongs to your Company (Header Name will be rejected by Operator id it does not satisfied with the proof).
Once the Header is approved, It will be ready to use.
Registration on the Jio platform
Jio (Website for Signup) https://trueconnect.jio.com/#/
Steps for Registration on JIo - Click here
Guide for Consent Templets and Consent Upload
Vodafone idea, MTNL, BSNL Guidelines
Vodafone Idea (Website for Signup) - https://www.vilpower.in
MTNL (Website for Signup) - https://www.ucc-mtnl.in/
Vodafone idea, MTNL & BSNL DLT Consent Template Guide
Vodafone idea, MTNL & BSNL DLT Consents Upload Guide
Airtel Guidelines
https://www.airtel.in/business/commercial-communication/help
Click on Content Template Registration
Click on Consent Migration
Click on Consent Template Migration
Airtel Guidelines for the validation and verification of content templates
Notification by Government
THE TELECOM COMMERCIAL COMMUNICATIONS CUSTOMER PREFERENCE REGULATIONS, 2018
DLT Scrubbing Charges
Further, the Telecom operators have released formal communications on charging an additional charge of Rs. 0.025(2.5p) per SMS on submission basis for all the traffic that is handed over to the DLT platform from 1st August 2020. The surge price will be charged irrespective of the message type or delivery status. This price revision will be over and above the existing commercials, agreed with Zixfow.
How to add Template on the Zixflow Platform
To comply with the new regulation you need to follow below 2 steps
1) Add Principle Entity ID
When you register on the operator you will get a unique entity ID (PE id). Update the ID into the SMS template.
2) Add Templates which are registered and approved on DLT
For more assistance on this matter, you can get in touch with our support team.
You can add templates in 2 ways:
Click on Add Template to add one by One.
To upload in Bulk, Click on Import and upload all the files.
If you are using API, there will be no changes required in the message submitting process from your end. We will append these DLT parameters to the messages while submitting to the Operators.
You need to upload or add all your templates in the Zixflow Platform under Campaign>Template Section, Update Principle Entity ID in profile. We will map these details in our system and once mapped, we would match your message text to the nearest matching template ID and submit your entity ID and template ID parameters to the operator DLT platforms for scrubbing.
This will be an ongoing process and when you add any template to your entity, you have to share/update the same in our system too.
Type of Templates
Categories of Messages/calls:
1. Transactional
2. Service-Inferred/Implicit
3. Service Explicit
4. Promotional
Transactional message
Any message which contains One time Password (OTP) and requires to complete a banking transaction initiated by the bank customer will only fall under the category transactional. This will be applicable to all banks, national/Scheduled/Private/Government and even MNC banks.
Illustration of the transactional message:
OTP message required for completing a Net-banking transaction.
OTP message required for completing credit/debit card transaction at a Merchant location.
Service Inferred /Implicit
Service Message (Inferred Consent): Inferred Consent has been defined in the Regulation as a permission that can be reasonably inferred from the customer’s conduct or relationship between the Recipient and the Sender. Thus, any message, arising out of customer's actions or his relationship with the sender, that is not promotional, and is not in the interest of the customer to block such communications, will be considered as a service message with inferred consent. These messages may or may not be triggered by a subscriber-initiated transaction and will not be blocked for subscribers who have otherwise blocked service messages also.
Illustration of Service Message (Inferred Consent):
Confirmation messages of a Net-banking and credit/debit card transaction.
Product purchase confirmation, delivery status etc. from e-commerce websites.
Customers making the payment through Payment Wallet over E-Commerce website/mobile app and an OTP is sent to complete the transaction.
OTPs required for e-commerce websites, apps login, social media apps, authentication/verification links, securities trading, demat account operations, KYC, e-wallet registration, etc.
Messages from own TSP
Periodic balance information, bill generation, bill dispatch, due date reminders, recharge confirmations (DTH, Cable, Prepaid Electricity recharges etc.)
Delivery notifications, feedbacks, periodic upgrades and updates
Messages from retails stores related to bill, warranty
Messages from schools - attendance/transport alerts
Messages from hospitals/clinics/pharmacies/radiologists/pathologists about registration, appointment, discharge, reports
Confirmatory messages from app-based services.
Government/DoT/TRAI mandated messages, advisories, messages from State Govt., LEAs, Local Authorities, Traffic advisories, Election Commission, Disaster Management advisories.
Service updates from car workshops, repair shops, gadgets service centers.
Directory services like JustDial, Yellow Pages.
Day-end/month-end settlement alerts to securities/demat account holders
Service Message (Requiring Explicit Consent)
Explicit Consent has been defined in the regulation as consent that has been verified directly from the Recipient in a robust and verifiable manner and recorded by Consent Registrar as defined under these regulations.
Thus, any service message which doesn’t fall under the category of service message (inferred consent) will be sent only against explicit, digitally verified/verifiable consent to service message blocked (having preference ‘0’ i.e. fully blocked) subscribers. There may not be any need for explicit consent to all other subscribers, who have not blocked service messages.
Promotional Message
As per the Regulation, Promotional messages means commercial communication message for which the sender has not taken any explicit consent from the intended Recipient to send such messages.
Thus, any message sent with an intention to promote or sell a product, goods or service. Service content mixed with promotional content will also be treated as promotional. These messages will be sent to the customer after performing the preference and consent scrubbing function as defined in the Regulation.
Templates Validation points
Organization name or their brand name must reflect either in the header or in the template. However, if any exceptions are to be allowed, TSP may seek justification for the same.
Transaction Content Template is only available for banks, digital wallets duly permitted/approved by RBI .
Transactional template should contain banking related OTP messages only as defined in the definition.
Service implicit communication type template to contain service messages only and should have any kind of promotion or- product updates both in the fixed as well as variable component of the message/call.
For banking entities, implicit messages may contain any service SMS other than OTP.
For non-banking entities, implicit messages may contain all types of service SMS including OTP.
Any Service implicit template should not contain any content such as insurance/car service renewal, birthday/festival wishes, any kind of offer like eligible for loan, limit enhancement, get cashback wherein anything is being offered to the receiver.
All such templates wherein some promo is being offered to the customer from an alphabetic sender id must have service explicit communication type.
All such templates wherein some promo is being offered to the customer from a numeric sender id must have promotional communication type. Eg. If HDFC Bank wants to send purely promotional messages, the header has to be numeric.
All promotional or service explicit templates must have consent ID against them which will reflect on the portal- this is optional now.
The customer can mention {#var#} in the template wherein changes are required, no other value will be considered.
The whole template should not be variable {#var#}, the customer is require to mention the template content in between the variables. Overall content to reflect the category of message the PE is wanting to send. Eg.
Suggested to keep variable length 20 for each variable
4-5 variables in transactional message
4-5 variables in service message
2-3 variables in promotional messages
The content template should not contain double quotes (") special characters as it created problems in storage and display. Will not be treated correctly. Other special characters are fine.
For each language vernacular scripts to be added separately on DLT. Unicode scripts cannot be uploaded.
The fixed part of content is that part of content which is common across all commercial communications sent to different recipients for same or similar subject; The variable part of content is that part of content which may vary across commercial communications sent to different recipients for same or similar subject on account of information which is very specific to the particular transaction for a particular recipient or may vary on account of reference to date, time, place or unique reference number; The template can be either fixed or a it may be a combination of fixed part of content and variable part of content. Templates with variable content only are not allowed.
If PE uses the name of another entity in their templates, the TSP’s shall register the same on the presumption that there exists a business relationship with that entity without TSP having any accountability to validate the same. Valid proofs and justification if sought pursuant to any complaints by TRAI/PE shall have to be furnished by the registering PE.
DLT FAQ
What is the difference between Transactional SMS and Service Implicit?
Transactional message: Any message which contains One time Password (OTP) and requires to complete a banking transaction initiated by the bank customer will only fall under the category of transactional.
Service Implicit: Any message, arising out of customer's actions or his relationship with the sender, that is not promotional, and is not in the interest of the customer to block such communications.
What is the content template format?
While creating template, place {#var#} string as variable.
For promotional SMS we have to do the same procedure to whitelist the SMS?
Yes, Every message needs to be whitelisted on the DLT platform. Currently, we suggest to upload promotional templates which are on going and will use in future too
What is a consent template?
Consent Template: Standard message that is sent to end users of the enterprise for their consent to receive communications from respective enterprises.
Consent Template is bifurcated into 3 sections:
Template name: Name as per choice
Brand Name: The product/trade name or if they have multiple brand names
Scope of consent: Content they want to send to end users (We would like to send communication regarding all marketing offers and events to our registered customers. {opt-out procedure can also be given}). It should not contain any actual message contents.
Example:
1. Would Like to Send Communication Regarding All Marketing Offers and Events to Our Registered Customers
2. We will send you updates, transactions, recommendations of our services or products being a registered customer with us.
What will happen while sending promotional SMSs if we follow the template but miss it by 2-3 characters? Do we have to strictly follow the template word to word?
We recommend to use variable (i.e. {#var#} ) where you expect changes. Constant part of the template expected to be as it is.
Shall we have to update temp on every telecom (DLT) platform or we have to upload on any one platform?
The template can be uploaded on any one operator's DLT platform and it will internally sync with other DLT platforms.
Do we have to upload a template on Zixflow? Or directly we have to upload the temp on the DLT platform?
Till DLT goes live with template scrubbing, you have to upload templates on both the platform (ie Zixflow & DLT)
Messages to registered clients like offers or information about products will be considered as Explicit or Implicit?
Service explicit
I, as a company, is the principle entity and Zixflow would be my telemarketer?
Yes, any company who is a generator of messages has to register as a Principle entity and need to tag their platform providers (TM) who take care of delivery of these messages.
So far we have approximately 10-15 templates whitelisted in the Zixfow portal, which falls under Transactional message. Now, do we need to re-register all those whitelisted templates in Telecom Service Provider portal as well, or will this new format apply to newly created templates that we would like to whitelist in future?
You have to upload all existing & new templates on one of the DLT platforms. Also, templates need to be registered for all types of messages (i.e. Transactional, service & Promotional).
Do we only have to register a template once?
All ongoing & new templates need to be registered on the DLT platform. This will be an ongoing activity.
Template uploading is a time consuming process. Is there any option to upload templates in bulk? Does the DLT have any API configurations as we have a lot of templates.
As of now we have not seen any option with which templates can be uploaded in bulk or API. If the operator releases any new feature in future then we will update.
How long does it take to whitelist the templates? What is TAT for template whitelisting?
TAT depends upon the load of template request, however you can expect response within 48 hrs.
So because of DLT, now we have to login in either Vodafone, Reliance or BSNL to send SMS to our end user?
DLT platform will use header, templates & consent management. For sending out the messages, you have to connect with one of the service/platform providers like Zixflow.
What is Principle entity & Telemarketers?
Principle Entity (PE):- A commercial business (individual or company) dealing with products or services, who would like to communicate with their customers through SMS or voice.
Telemarketer (TM) :-Telemarketer Aggregator: An individual or a company who collects SMS/voice traffic from enterprises, but DOES NOT have direct connection with telecom operators.
Telemarketer Delivery: An individual or a company who collects SMS/voice traffic from enterprises, and has direct connection with telecom operators.