TRAI consent for calling customers, and when it expires

A driving school calls a lead who filled out an enquiry form six weeks ago, to follow up on a batch starting next month. The owner is confident this is fine — the person gave their number, after all. Whether it actually is fine depends on facts most businesses never separately check: what kind of consent was recorded, what the caller told the person it would be used for, and, since February 2025, how long ago it was given.

'We have consent' gets treated, in TRAI's framework, as one of several distinct legal states rather than a single yes-or-no switch. A business that collapses those states into one idea is the one most likely to end up calling on the wrong side of the line without ever realising it, because nothing about the call itself feels different when the underlying consent basis has quietly lapsed.

The Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) is the framework the Telecom Regulatory Authority of India uses to govern commercial calls and messages — what the regulations call Unsolicited Commercial Communication when it happens without permission. It set up the National Customer Preference Register, commonly called the DND registry, where a phone number holder can opt out of commercial communication entirely or by category.

Two distinct forms of permission let a business reach someone regardless of a DND registration. Inferred consent arises out of an existing relationship — someone who already has a service contract with a business can reasonably be contacted about that specific relationship, and this kind of consent lasts for the duration of that contractual relationship, not indefinitely. Explicit consent is different in kind: it has to be verified directly from the recipient and recorded through a registered Consent Registrar on the telecom operator's own Distributed Ledger Technology platform, not simply noted in a business's own CRM. A number on the DND registry can still be legally called for a category it has explicitly consented to — which is the entire reason explicit consent exists as a separate track — but that track has its own rules, and one of them changed materially in 2025.

On 12 February 2025, TRAI notified an amendment to TCCCPR that specifically addressed how long explicit consent lasts once given. Multiple legal-compliance summaries of that amendment — cross-checked against each other as of 16 August 2026, since the notification's own PDF text was not machine-readable through the tools available while researching this article — describe the same figure: the validity of explicit consent taken for fulfilling a commercial transaction is seven days from the date the consent was acquired.

After that window, the consent record does not vanish from the DLT platform, but it stops being a valid basis for the specific transactional call or message it was collected for. A business that captured explicit consent from a customer eight days ago, and is now placing a follow-up call on that basis, is not relying on stale-but-forgivable consent — it is relying on consent that has already lapsed for that purpose. The intuitive assumption this amendment corrects is exactly the one most businesses start with: that once someone says yes, a business can keep calling on that basis indefinitely. The distinction that matters is between consent given for a transaction and consent tied to an ongoing registered relationship; the seven-day clock applies specifically to the former, while inferred consent tied to an existing contract runs on its own separate, relationship-length basis.

It's tempting, once one specific number like seven days is confirmed, to assume every other figure circulating in TRAI compliance guidance is equally solid. It isn't. A commonly repeated claim is that TRAI restricts commercial calls to a 9 AM–9 PM window. This may reflect genuine practice among compliant telemarketers, and it's the window a cautious business should probably default to regardless — but a specific, citable TRAI regulation fixing exactly those two clock times could not be independently confirmed against a primary regulatory source in the time available for this article.

Where a number this specific circulates widely without a citable source attached, the responsible thing to do is say so rather than repeat it as settled law. Any business — including a calling product enforcing a fixed window as its own policy — should be clear with its customers about whether that window is a citation of TRAI regulation or the business's own, more conservative choice. Confusing the two is exactly the kind of small inaccuracy that compounds into a false sense of regulatory certainty.

Beyond the expiry point, TRAI's framework is specific about what makes consent 'explicit' rather than merely assumed. It has to be recorded, not just claimed — meaning it exists as a discrete, retrievable entry through a Consent Registrar on the DLT platform, tied to the specific customer, the specific purpose or category (promotional, transactional, service), and the specific sender registered to use it.

A verbal yes on a sales call, written down only in a spreadsheet the business controls, is not the same thing as explicit consent in TRAI's sense, however honestly it was obtained — it is missing the verification and registration step the framework requires before it can override a DND preference for that number. This is a common point of confusion for a small business used to thinking of consent purely as an internal, honesty-based record: TCCCPR treats it as an infrastructure-verified fact, not a business's own assertion about what a customer agreed to.

The practical implication for anyone calling customers, at any scale, is that consent needs to be treated the way an expiring credential is treated elsewhere in a business — checked at the point of use, not once at the point of collection. A lead captured eight days ago is not covered for a transactional follow-up call today under the seven-day rule, even though the same contact may still be covered under an inferred-consent basis if an actual contractual relationship now exists.

Building this into a calling workflow means checking category and consent freshness immediately before every dial, rather than trusting whatever was true when the contact was first added to a list. A platform like Wani re-checks consent at the moment a call is queued for exactly this reason — but the underlying discipline, checking rather than assuming, is the one any business calling its own customers needs to build in, with or without a product enforcing it structurally. None of this substitutes for a telecom compliance professional's read on a specific campaign; TRAI updates this framework periodically, and a business planning a large calling campaign should check TRAI's own current published regulations before relying on any consent basis at scale.