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September 14, 2025
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TCCCPR 2018 and India’s A2P SMS Market: Impact, Paradoxes, and Policy Options

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A2P SMS vs OTT

1) What TCCCPR 2018 Changed

Core instruments.

  • Distributed Ledger Technology (DLT): Mandatory registration of principal entities/telemarketers, headers, content and consent templates with access providers. TRAItrubloq.comInfobipospconsultant.com
  • Consent & preference: Movement toward digital consent acquisition (DCA) and fine-grained recipient preferences; complaints are easier to file and action thresholds were tightened. TRAISaraf and PartnersSecuriti
  • Enforcement: Graduated penalties on access providers and senders; tightened definitions around promotional vs. service/transactional traffic; new header/category suffix requirements. Mondaqtanla.com

Observed market effects.

  • Higher compliance overhead (KYC, template vetting, header restrictions, scrubbing) and campaign lead-time increased for legitimate brands—especially SMEs—while grey senders were squeezed out. Infobipospconsultant.com
  • Spam reduction via complaint-driven blocking and traceability improved user trust, but also created conversion friction for consented marketing (re-collecting digital consent, template rejections, header suffix changes) that can depress reach. Securititanla.com

2) Meanwhile on Social: Autoplay & Ambient Advertising

Instagram Reels & Facebook feeds: Full-screen looping ads (with social interactions) were introduced in Reels, presenting marketing content intermingled with organic video—encountered by default during viewing, not by explicit opt-in per advertiser. The Times of India

WhatsApp’s shift: In 2025, Meta began introducing ads in the Updates/Status/Channels surfaces (not in private chats), plus paid channel promotion—again encounter-based rather than sender-specific opt-ins. This coincides with a new per-message pricing regime for WhatsApp Business that encourages more paid outreach within Meta’s policy guardrails. Business InsiderThe TimesWhatsApp Business

Disclosure & transparency baseline: India relies on the ASCI Influencer Guidelines (disclosure labels like “Ad/Sponsored/Collab”) and Consumer Protection rules, but enforcement is uneven; many digital endorsements still lack proper disclosure. ASCI+1BW Marketing World

Privacy law context: The DPDP Act frames consent as free, specific, informed, unambiguous, and affirmative, with easy withdrawal—standards that should apply to behavioral tracking and ad targeting, although actual platform UX often relies on broad, bundled consents. S.S. Rana & Co.

Asymmetry in user experience:

  • A2P SMS requires prior, template-matched, DLT-recorded consent to deliver promotional content.
  • Social ads are algorithmically inserted into attention streams; the “consent” is typically platform-level and bundled, not brand-specific or campaign-specific—so viewers are made to watch or at least skip through marketing content without a per-advertiser opt-in. The Times of IndiaBusiness Insider

3) Impact on India’s Promotional A2P SMS Business

  • Compliance costs & latency: DLT onboarding, content and consent template approvals, and header suffix changes introduce delays and non-trivial operating costs—especially for SMEs and regional marketers—reducing SMS’s agility vis-à-vis social ads. Infobiptanla.com
  • Deliverability risk: Stricter scrubbing and complaint thresholds increase the risk of legitimate campaigns being throttled/blocked over minor consent/template issues. Securiti
  • Channel substitution: As friction rises, market spend tends to drift toward friction-light social surfaces (Reels/Feeds/Status/Channels) and Click-to-Message funnels, where consent is ambient and ad-tech optimization is mature. The Times of IndiaBusiness Insider

4) Findings: A Policy Paradox

  • TRAI’s regime has made SMS promotion more lawful and traceable but less competitive against platforms where ad exposure is ambient and consent is bundled or inferred at platform sign-up—despite India’s high bar for consent in DPDP. TRAIS.S. Rana & Co.
  • Consumer protection goals are laudable; however, channel-biased friction risks pushing marketers to ecosystems with weaker per-sender transparency (and heavier algorithmic influence), even as social surfaces expand ad load. The Times of IndiaBusiness Insider

5) Recommendations for TRAI (and Industry)

A. Make consent workable without diluting protection

  1. Interoperable, channel-agnostic consent registry: Allow brands to port verifiable consent across licensed access providers and CPaaS players (with revocation honored everywhere) and recognize DPDP-grade consents collected off-channel (e.g., website/app) if cryptographically attested into DLT. TRAI
  2. Standardized, low-latency DCA UX: Publish mandated DCA UI patterns (language, timing, retries, expiry) and SLA targets for consent writes/reads to reduce message launch latency for compliant marketers. TRAI
  3. Grace for verified relationships: For existing customer relationships, allow purpose-bound, limited-frequency promotional outreach under “soft opt-in”, provided opt-out is one-tap and logged to DLT. (Mirrors global best practices while keeping auditability.) Inference based on current definitions and amendments. Mondaq

B. Align definitions and disclosures across channels
4) Harmonize “promotional” definitions and disclosure cues across SMS, Reels, and Status/Channels to address the perception gap where social ads feel less “consented” than SMS promos that already carry explicit opt-ins. Coordinate with ASCI and consumer protection authorities for uniform, legible disclosures and easy complaint routing. ASCI+1

C. Precision enforcement instead of blanket friction
5) Risk-based throttling: Use complaint-rate and anomaly detection to target bad actors rather than imposing blanket template/consent hurdles that slow everyone. Keep the lower complaint thresholds but pair them with faster rectification for first-time offenders. Securiti
6) Predictable template governance: Publish open test suites and versioned rulebooks for content/header validation so marketers can self-certify before submission; minimize business disruption from suffix/category changes by offering transition windows. tanla.com

D. Consumer experience & redressal
7) Unified opt-out: A single, channel-agnostic “Do-Not-Disturb-Promo” toggle that writes to DLT and signals to major platforms via API (in coordination with MeitY/DPDP Data Fiduciaries) would give users real control—regardless of channel. Inference aligned with DPDP consent/withdrawal norms. S.S. Rana & Co.

6) Conclusion

TCCCPR 2018 and its 2025 amendments did suppress SMS spam and improve accountability—but, by imposing high-friction consent mechanics and strict templating, they unintentionally disadvantaged compliant A2P marketers versus social platforms where ads are encountered by default (Reels, Feeds, and now WhatsApp Updates/Status). A modernized, interoperable digital consent layer, harmonized disclosures across channels, and risk-based enforcement can preserve consumer protection and restore SMS to a fair footing in India’s omnichannel marketing mix. TRAIThe Times of IndiaBusiness Insider

Key Sources

Author’s note

This brief takes a policy-neutral stance on consumer protection: keep the guardrails, reduce unnecessary friction, and equalize disclosure/consent expectations across channels so that law-abiding mobile marketers are not competitively penalized while users retain simple, universal control over their attention.

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