What are transactional (service-implicit) vs promotional calls under TRAI, and what rules apply to DND numbers?

What are transactional (service-implicit) vs promotional calls under TRAI, and what rules apply to DND numbers?

⚡ Quick answer

• Transactional ( “service-implicit” ) calls are informational only—OTPs, alerts, booking or order-status updates—for registered customers. They must not contain any marketing content.

• Promotional calls advertise or promote a product or service, even to existing customers.

• DND numbers:– Transactional calls are allowed if the recipient is an existing customer and you hold valid consent.– Promotional calls are prohibited to DND numbers unless you have explicit opt-in proof via Digital Consent Acquisition (DCA) / other validated opt-in evidence.

• Promotional calls may be placed only between 09:00 AM and 09:00 PM, Monday–Sunday.

When should I use this guide?

Read this before launching any voice-call campaign from MyOperator (or another platform), so you stay fully compliant with TRAI/DLT rules on transactional vs promotional traffic and Do-Not-Disturb regulations.



1. Definitions at a glance

Call type

Definition

Key characteristics

Service Implicit (Transactional)

“Informational calls like OTPs, alerts, bookings, and order status updates for registered customers. They must not be used for marketing purposes.”

• Purely informational

• Linked to a service or product the customer requested or is using

• No promotional content

Promotional

“Any call that promotes or advertises a good or service, regardless of whether the call is made to an existing or potential customer.”

• Unsolicited marketing offers, discounts, product pitches

• Can target existing or non-existing customers



2. DND rules for each call type

Scenario

Allowed to DND?

Citation

Transactional call to an existing customer with valid consent

✅ Yes

“Transactional calls are permitted to DND numbers if the recipient is an existing customer and valid consent exists.”

Transactional call to a non-customer

❌ No

“Transactional calls cannot be made to individuals who are not current clients.”

Promotional call to any DND number without explicit consent

❌ No

“Promotional calls to DND numbers are strictly prohibited unless the caller has explicit consent through DCA.”

Promotional call to DND number with opt-in proof/DCA

✅ Yes

“Only if the caller has valid opt-in proof or communication history.”



3. Timing window for promotional calls

• “Promotional calls are only allowed between 9:00 AM and 9:00 PM, Monday through Sunday.”

• There is no time-of-day restriction specifically called out for transactional calls.



4. Examples of promotional calls

  1. Calling a potential customer: “Dear Sir, from BuyUsOrElse, this is Kumar. May I tell you about our new product XYZ?”
  2. Calling an existing customer: “Dear Mr Kumar, as a thank-you for using our services, we are offering you a discount on our latest product ABC.”

Both examples promote a product, so they fall under promotional-call rules.



5. Compliance checklist

  •  Is the content strictly informational (OTP, alert, booking) → mark as Transactional.
  •  Is there any marketing element (offer, discount, upsell) → mark as Promotional.
  •  For transactional calls:
    • Recipient is an existing customer.
    • Valid consent on record.
  •  For promotional calls:
    • If the number is on DND → explicit opt-in proof/DCA captured.
    • Call scheduled between 09:00 AM – 09:00 PM.
  •  Call complies with DLT & TRAI tagging on the MyOperator system.