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telemarketer in dlt

Telemarketer

Under the Telecom Commercial Communications Customer Preference Regulations (TCCCPR), 2018, a Telemarketer is defined as any individual or legal entity that transmits or delivers commercial communication — including SMS, voice calls, or other promotional content — on behalf of businesses or for their own services. These activities are strictly regulated to curb spam, ensure customer privacy, and maintain transparency in commercial messaging.
 

Telemarketer Registration

  • Registered Telemarketer (RTM):

  • To legally carry out telemarketing activities, telemarketers must register with Access Providers (telecom operators). This registration ensures that all commercial communications are monitored, compliant, and traceable under regulatory frameworks such as TRAI’s TCCCPR, 2018. Without this registration, telemarketers are not authorized to send any form of commercial communication.

  • Unregistered Telemarketer (UTM):

  • An Unregistered Telemarketer (UTM) refers to any individual or entity that transmits commercial communication without proper registration on the DLT platform. Such activity is considered a violation of telecom regulations. If a UTM is found sending unauthorized messages, their telecom resources — such as phone numbers or SMS routes — may be restricted, blacklisted, or permanently disconnected to prevent misuse and protect consumer interests.

Distributed Ledger Registration for Telemarketers

Telemarketers function within the Distributed Ledger Technology (DLT) framework, which is designed to ensure transparency, traceability, and regulatory compliance across all commercial communications.

  • All telemarketers are required to register in the Distributed Ledger for Entities (DL-Entities). This ledger securely maintains telemarketer details, ensuring that only verified and authorized entities can operate.

  • Upon registration, each telemarketer is assigned a unique Telemarketer ID, enabling their activities to be tracked and monitored throughout the DLT ecosystem, thereby promoting accountability and minimizing misuse.

Scrubbing of Telemarketer Messages

Before dispatching any commercial communication, telemarketers must scrub their recipient lists against two critical DLT repositories:

  • DL-Preference: Verifies that messages are not sent to individuals who have opted out or blocked specific categories of communication.

  • DL-Consent: Confirms that messages are sent only to recipients who have explicitly provided consent, even if they’ve opted out of certain message types.

This mandatory scrubbing process ensures strict compliance with user preferences and helps prevent Unsolicited Commercial Communication (UCC), maintaining both legal and ethical standards.

Functions of Telemarketers

Understanding the Two Types of Registered Telemarketers: TM-AF and TM-DF

In the world of regulated commercial communication, Registered Telemarketers (RTMs) play a crucial role in ensuring everything runs smoothly, transparently, and in compliance with the rules. RTMs fall into two main categories: Telemarketer for Aggregator Function (TM-AF) and Telemarketer for Delivery Function (TM-DF). Each type has its own unique responsibilities within the Distributed Ledger Technology (DLT) framework.

1. Telemarketer for Aggregator Function (TM-AF)

Overview:

TM-AFs manage the backend operations and regulatory setup for Principal Entities (PEs). They act as the bridge between PEs and Access Providers, making sure all the necessary requirements for messaging are met.

Core Responsibilities:

  • DLT Registration: They need to be registered on the DLT platform to represent PEs in managing messages and consent.

  • PE Account Management:
    Oversee and support PEs in:

    • Registering Headers (Sender IDs) for SMS and CLI for voice.

    • Uploading and managing Consent Templates.

    • Managing and submitting Content Templates for regulatory approval.

  • Scrubbing Initiation:
    Responsible for initiating message scrubbing against the DND registry to ensure compliance before delivery.

  • Repository Management:
    Maintain records of headers, consents, and templates for audit trails and compliance checks.

2. Telemarketer for Delivery Function (TM-DF)

Overview:
TM-DFs are tasked with the final delivery of communications — making sure the right messages reach the right recipients securely and legally.

Core Responsibilities:

  • DLT Registration:
    Must register on the DLT platform with appropriate telecom connectivity to carry out message delivery.

  • Scrubbed Delivery Execution:
    Using the scrubbed list from TM-AF, TM-DF initiates message delivery exclusively to non-DND recipients.

  • Message and Voice Delivery:

    • Sends SMS to compliant recipient lists.

    • Delivers voice calls using registered CLI routes.

  • Communication Records:
    Maintains detailed logs of all delivered communications, ensuring traceability for audits, legal compliance, and customer queries.

Obligations of Telemarketers

Under the Telecom Commercial Communications Customer Preference Regulations, 2018, telemarketers must follow strict guidelines to ensure transparent, compliant, and user-respecting communication. Here’s what’s required:

1. Respect Do Not Disturb (DND) Preferences

Telemarketers must strictly avoid contacting customers who have:

  • Opted out of specific communication categories.

  • Subscribed to the Fully Blocked DND list.

Exception: Messages can only be sent to these customers if explicit consent is recorded and approved in the DLT system under DL-Consent.

2. Use of Registered Headers

Every telemarketer must use DLT-registered headers, which are:

  • Alphanumeric identifiers assigned to identify the sender and message type (e.g., promotional, transactional, service).

  • Required for both SMS and voice communication.

  • Mapped and approved under the entity’s DLT profile.

This helps recipients and regulators identify the origin of messages and maintain trust in communications.

3. Complaint Monitoring via DL-Complaints

Telemarketers are responsible for actively monitoring and resolving any complaints lodged against them. Key points include:

  • All complaints are recorded in the Distributed Ledger for Complaints (DL-Complaints).

  • Repeated violations — especially those involving messages sent to DND users without consent — can result in serious consequences such as:

    • Fines

    • Suspension of services

    • Permanent disconnection of telecom resources (e.g., headers, numbers, accounts)

By following these practices, telemarketers maintain regulatory compliance while safeguarding their business continuity and customer trust.

Penalties for Non-Compliance

  • If a telemarketer is found in violation of the regulations by sending unsolicited communications or not adhering to customer preferences, several penalties can be imposed:

    • First Violation: A warning is issued to the telemarketer.

    • Second Violation: The telemarketer may be placed under a Usage Cap, which limits the number of outgoing messages or calls.

    • Subsequent Violations: The telemarketer’s resources (phone numbers, messaging capabilities) may be disconnected for up to two years, and the entity may be blacklisted, prohibiting further registration.

Usage Cap for Violations

​​Telemarketers who repeatedly violate the regulations can be placed under a Usage Cap, which limits their ability to send messages or make calls. This cap restricts the number of outgoing communications they can make per day and is typically enforced when a significant number of complaints are received against the telemarketer.

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