Renewal and servicing calls belong on the 1600 series. New business and cross-sell belong on 140. Ordinary 10-digit mobile numbers are restricted for commercial calling, and the deadline to move was 1 January 2026.
If your renewals desk still dials policyholders from ordinary mobile numbers, you are outside the rules — and have been since January. Most brokers we speak to do not know this changed. Most vendors selling them dialers have not mentioned it.
There is also a part nobody mentions, and it is the part that should actually make you move: compliance will probably raise your connect rate, not cost you one.
What changed
TRAI notified amendments to the Telecom Commercial Communications Customer Preference Regulations (TCCCPR) on 12 February 2025, published in the Gazette on 18 February 2025. Most provisions took effect 30 days after publication; Regulations 8, 17, 20(a–b) and 21(b) took 60 days.
The headline change is simple, and it is the one that catches brokers:
Ordinary 10-digit numbers are restricted for commercial calling.
Not "restricted above a certain volume." Not "restricted for bulk campaigns." Commercial calling moves to designated number series. For insurers and other IRDAI-regulated entities, TRAI’s direction of 16 December 2025 set the deadline to move service and transactional calls onto 1600 at 15 February 2026. That date has passed.
The two series, and which one you need
This is where most people get it wrong, because insurance uses both — for different calls.
| 140 series | 1600 series | |
|---|---|---|
| Purpose | Promotional and marketing | Service and transactional |
| Who can use it | Registered entities, all sectors | Regulated BFSI entities and government |
| Insurance examples | New business, cross-sell, upsell, lead follow-up | Policy renewals, payment alerts, OTPs, regulatory notifications |
| DND / preference filtering | Applies — scrub before every call | Does not apply |
| Can the call be blocked or tagged? | Yes | No |
A related series, 1601, was designated for utilities and logistics companies. Not relevant to insurance, but worth knowing it exists so you are not mis-sold it.
The distinction that matters for brokers
Renewal reminders to an existing policyholder are service communications. They belong on 1600, and policy renewals are named explicitly as a use case for the series.
Calls to someone who is not yet your customer are promotional. Those belong on 140, and they require DND scrubbing before every single call plus a verifiable consent record.
If you are running both kinds of call off the same regular mobile numbers — which is what most renewals desks do — you have a compliance problem on both halves at once.
The upside nobody mentions
Here is the part that turns this from a cost into an advantage.
Calls originating from the 1600 series cannot be tagged, blocked, or filtered. Customers cannot DND them away. Handset spam-labelling does not apply.
Think about what renewal calling looks like today from a regular 10-digit number: an unknown mobile, often flagged "Spam Risk" by the recipient's phone, competing with every other unknown caller for attention.
Now consider the same call from a number the network is required to deliver, that cannot be silently filtered.
Moving renewal calling to 1600 is not a compliance tax. It is a deliverability upgrade that happens to also be the law.
What does non-compliance cost?
The amendments tightened both the complaint mechanism and the penalties.
Complaints got easier to file and faster to bite
- The complaint window was extended to 7 days
- The action threshold dropped to 5 complaints within 10 days — previously 10 complaints within 7 days
Financial disincentives on access providers
These sit on your telecom provider, and flow down to you through them.
- ₹1,000 per valid complaint wrongly dismissed
- ₹5,000 per improper header or content template registration
- Misreporting: ₹2 lakh first instance, ₹5 lakh second, ₹10 lakh subsequent
Service suspension for repeated violations
- First offence: 15-day bar on outgoing services
- Subsequent: one-year disconnection and blacklisting across all providers
Read that last line again. Not a fine — a year, across every operator.
And there is a second regulator
Non-compliance may draw action not only from TRAI but from sector regulators including IRDAI, RBI and SEBI.
For a broker, that is the real exposure. A telecom penalty is a cost. An IRDAI file is a different category of problem, and it lands on the licence you spent years obtaining.
What to actually do
- Separate your call types. Renewals, payment reminders and policy servicing are service calls. New business, cross-sell and lead follow-up are promotional. Most desks currently run both through one queue on one set of numbers. That has to split.
- Get onto the right series. Service calling to 1600 through your provider. Promotional calling to 140.
- Register on DLT. Every commercial caller must be registered on the Distributed Ledger Technology platform before making outbound calls. Headers and content templates register there too.
- Scrub DND before every promotional call. Not once a month. Before every call. This does not apply to your 1600 traffic.
- Keep verifiable consent records. Explicit consent must be captured in a robust and verifiable manner. Note the sharp limit: explicit consent for service communications facilitating a transaction is valid for a maximum of 7 days. Consent gathered last year does not cover a call you make today.
- Respect calling hours. Promotional calls are restricted to permitted hours.
Where AI voice agents fit
If you are evaluating AI calling for renewals, the regulation should be your first question to any vendor, not your last.
An AI agent making thousands of calls a day from ordinary 10-digit numbers is not a clever workaround. It is the same violation at higher volume, with a clearer audit trail — and the complaint threshold is now five in ten days.
Questions worth asking any vendor:
- Which number series will my calls originate from?
- Are you registered on DLT, or am I expected to be?
- How is DND scrubbing handled on promotional traffic, and how often?
- How are consent records captured and stored, and for how long?
- If a complaint is filed, what evidence can you produce?
If a vendor cannot answer the first question immediately, that tells you what you need to know.
The short version
- Ordinary 10-digit numbers are not available for commercial calling. The 1600 deadline for IRDAI-regulated entities passed on 15 February 2026.
- Renewals and servicing → 1600. New business and marketing → 140.
- 1600 traffic cannot be blocked or DND-filtered — compliance improves your connect rate.
- Five complaints in ten days triggers action. Repeat violations mean a year of disconnection across all providers.
- IRDAI can act, not just TRAI.
Common questions
Is it illegal to call customers from a normal mobile number in India?
For commercial communications, ordinary 10-digit numbers are restricted. Commercial calling belongs on the designated series — 140 for promotional, and 1600 for service and transactional calls by regulated BFSI entities. For insurers and other IRDAI-regulated entities, the 1600 adoption deadline was 15 February 2026.
Do insurance renewal reminders count as promotional calls?
No. Renewal reminders to an existing policyholder are service communications and belong on the 1600 series. Cross-selling a different product to that same customer is promotional and belongs on the 140 series.
Can customers block calls from the 1600 series?
No. Calls originating from the 1600 series cannot be tagged, blocked or filtered, and DND preferences do not apply to them. Customers can block 140-series promotional calls through the DND registry.
Does TRAI's number series rule apply if we only make a few hundred calls a day?
Yes. The restriction on using ordinary 10-digit numbers for commercial calling is not volume-based. It applies regardless of how many calls you place.
What are the penalties for non-compliant commercial calling in India?
Action is triggered by five valid complaints within ten days. A first offence carries a 15-day bar on outgoing services; repeat violations carry one-year disconnection and blacklisting across all providers. Sector regulators including IRDAI, RBI and SEBI may also act independently of TRAI.
Does using an AI voice agent change TCCCPR obligations?
No. The obligations attach to the commercial communication itself, not to whether a human or an automated system places the call. An AI agent calling from non-compliant numbering is the same violation at greater volume.
Sources
- TRAI — TCCCPR amendments notified 12 February 2025, published in the Gazette 18 February 2025
- TRAI — designated 140 and 1600 series frameworks for commercial communication
- TRAI Direction, 16 December 2025 — 1600-series adoption by IRDAI-regulated entities by 15 February 2026
- Telecom Commercial Communications Customer Preference Regulations, 2018 (as amended)
Facts verified 26 October 2026. This is a plain-English summary for insurance distributors, not legal advice. Confirm your specific obligations with your telecom provider and compliance counsel.
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