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TRAI calling windows (09:00–21:00 IST)

When you can and can't dispatch outbound calls under TRAI's TCCCPR 2018 — and how Cualify hard-gates the window so you don't have to think about it.

The rule in one line

Promotional and service-explanatory calls may only be placed between 09:00 and 21:00 IST. Transactional calls (OTPs, EMI reminders, appointment confirmations) are exempt and may be placed any time.

What counts as which category

Promotional · 09:00–21:00 only

  • Outbound sales (lead qualification, demo booking, upsell offers)
  • New-product announcements to existing customers
  • Marketing surveys not tied to a transaction
  • Loan/insurance offers not initiated by the recipient

Service-explanatory · 09:00–21:00 only

  • NPS / CSAT surveys following a service interaction
  • Renewal reminders > 7 days before due date
  • Educational content about a product the recipient already uses

Transactional · any time, 24×7

  • OTP delivery for authentication
  • EMI / invoice due-date reminders within 7 days of due date
  • Appointment confirmations and reschedules
  • Order / shipment status updates
  • Fraud or critical service alerts

The dividing line is whether a reasonable recipient would expect the call given an ongoing transaction with you. "You ordered a pizza, here's the delivery tracking call at 22:30" is transactional. "Hi, want to upgrade your phone plan?" at the same time is not — and the carrier will block it.

Loan recovery is stricter. RBI bars lenders and their agents from calling borrowers about overdue loans before 08:00 or after 19:00, whatever the TRAI category. Cualify holds every call from an agent marked Collections to 08:00–19:00 IST.

How Cualify enforces the window

Every campaign you create has a category field (promotional / service-explanatory / transactional). The dispatch path checks the category against the recipient's local time at dial:

  • Pre-launch validation: the campaign launcher refuses to schedule promotional / service-explanatory campaigns that would fire outside the window. You see the warning before you click launch, not after a TRAI strike.
  • Per-call gate: at dispatch time, we recompute the recipient's local IST time. Calls that drift across the 21:00 boundary mid-campaign go back to queued status and resume at 09:00 the next day.
  • Transactional bypass: if you set category=transactional, the gate is skipped. We log the override on the audit trail so a compliance review can confirm the category was set deliberately.

State-level variation

Some states have stricter windows around exam season (Tamil Nadu, Kerala) or local public holidays. Cualify ships the union of all state restrictions by default — 09:30–20:30 IST is the safe window if you want to never think about state-by-state nuances. Configure under /integrations/telephony → Calling window.

Public-holiday treatment

TRAI doesn't formally restrict promotional calls on national holidays, but carriers throttle aggressively and answer-rates tank ~30%. Cualify lets you pre-mark dates in Campaign settings → Holiday calendar; campaigns auto-pause and resume the next business day.

What happens if you violate

  • First violation: carrier flags your DLT entity; warning email from TRAI within 48h.
  • Second violation in 30 days: ₹10,000 fine + temporary suspension of your DLT header (24–72h).
  • Third violation: ₹25,000–₹50,000 fine + permanent header revocation; you have to re-register with a new entity.

Cualify's hard gate is designed to make all three impossible by accident. The only way to violate is to deliberately mis-classify a campaign — which the audit log makes visible to any reviewer.

What's next?