The Telecom Regulatory Authority of India (“TRAI”) on May 12, 2023, issued a direction to all the Access Providers to stop the misuse of Message Templates, under THE TELECOM COMMERCIAL COMMUNICATIONS CUSTOMER PREFERENCE REGULATIONS, 2018 (“TCCCPR2018”). It is stated that the Unsolicited Commercial Communication (“UCC”) is a major source of inconvenience to the public and impinges on the privacy of individuals and TRAI has been taking various steps to curb it. The Authority has directed all the Access Providers that the use of more than three variable parts in the contents shall be permitted only with proper justification and additional checks.

The TRAI has mandated that Access Providers shall have to designate a separate approving authority for such content templates. Each variable part needs to be pre-tagged for the purpose it is proposed to be used and a minimum of thirty percent of the message should comprise of the fixed part so that intent of the original message, for which the content template was approved, is not changed by the intermediaries. It has also been decided that only whitelisted URLs/APKs/OTT links/call back numbers shall be allowed in the content template. All the Telecom Service Providers have been directed to furnish a compliance report of the above direction within 45 (forty-five) days.

Please find below a detailed note on the requirements by the Access Providers:

1. Access Provider shall allow, in special circumstances and on requisition with reasons and proper justification from Principal Entity, more than three variables in the content templates,

   a. 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;

   b. 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;

   c. minimum thirty percent characters in the content template shall be fixed content.

2. Access Provider shall 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;
3. Access Provider shall ensure the use of only whitelisted URLs/APKs/OTT links/ call back numbers in the content template;
4. Access Provider shall ensure that, in case of an URL containing both fixed and variable parts, the fixed part of URL is whitelisted;
5. Access Provider shall monitor the use of content templates and further, stop any misuse of special templates; and
6. Access Provider shall 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.