TRAI launches Pilot Project for Digital Consent Management in Banking Sector

A Survey Report by LocalCircles in 2024, claims that 95% of spam complaints stem from promotional calls/messages. In a effort to curb unsolicited Spam Calls and financial frauds, TRAI has launched a Pilot Project for Digital Consent Management specifically for the Banking Sector. This project under a Regulatory Sandbox framework, is expected to setup the foundation for operational, technical, and regulatory aspects of Consent Registration Function (CRF) for other sectors as well and would expand the digital consent ecosystem.

The press release (Press Release No.48/2025) issued by TRAI in this regard ("Press Release") states that initially the Banking sector has been prioritized for first phase of implementation of the Digital Consent Management ("DCM"), given the sensitivity of banking transactions and cases of financial frauds through spam calls.

TRAI has launched this project in coordination with the Reserve Bank of India (RBI) and select banks.

The Projects requires establishment of a Consent Registration Framework ("CRF") which ensures acquiring digital consent by the entities and registering them in a secure and interoperable digital consent registry maintained by the Telecom Service Providers (TSPs) for easy verification of consents while commercial communication is made to the consumers.

On the subject matter the current regulatory framework defined by Telecom Commercial Communications Customer Preference Regulations (TCCCPR), 2018, an entity can make commercial communications to a consumer irrespective of his/her Do Not Disturb (DND) preferences provided the entity has taken explicit consent from the consumer.

However, it is difficult to ascertain validity and genuineness of consents collected through offline or unverifiable means. For example, often businesses acquire mobile numbers of their customers through misrepresentation, deception, or unauthorized data-sharing practices. TRAI has taken regulatory measures to curb such practices by introducing customer complaint mechanisms against unregistered telemarketers (UTMs) without the need of prior DND registration by customer, and mass disconnection of telecom resources of entities for misused for spamming activities.

TRAI has already issued two very critical amendments in the TCCCPR Regulations. Earlier this year in February 2025, TRAI introduced very critical amendments in the TCCCPR Regulations through the Telecom Commercial Communications Customer Preference (Second Amendment) Regulations, 2025. This Second Amendment introduced redefining commercial communication categories, strengthening consumer complaint redressal mechanisms, tightening the threshold norms for action against UCC, bringing in higher accountability of senders and telemarketers, curbing the misuse of 10-digit numbers for telemarketing, implementing tight measures against unregistered telemarketers (UTMs).

The Amendments also introduced category based "Message headers" with standardized identifiers for consumers to differentiate between promotional, service, and transactional messages. Distinctive suffix were added to message header for identification of headers for example: "-P"  for Promotional, "-S" for Service, "-T" for Transactional, and "-G" for Government messages.

The latest Press Release also emphasize the importance of onboarding entities sending commercial communications, for successful operation of Consent Registration Framework.

We see this as a welcome step towards developing a enhanced and robust Digital Consent Ecosystem for businesses in India.