Bulk SMS is an application-to-person messaging services wherein Bulk messages are triggered from an user interface linked to a telecom service provider often called as SMS gateway to ensure termination of messages to mobile phones numbers across the world.
Bulk SMS services have undergone lots of changes in the past few months owing to the implementation of DLT (Distributed Ledger Technology) by Telecom Operators, to comply with the guidelines published by TRAI (Telecom Commercial Communications Customer Preference Regulation 2018 (TCCCPR 18),telecom operators have started implementing compliance procedures effective 1st Sept 2020.
DLT implementation is undertaken in phased manner owing to the complexity and the scale involved and following are the planned milestones.
• Under Phase 1 to be live from 1st Sept 2020 TSP’s have made it mandatory for every entity / business to register its KYC information & Sender ids / Headers on any of TSP’s(Telecom Service provider's) DLT portal.
• In the phase 2 live on 19th Nov 2020, Telecom operators made it mandatory for entities / businesses to ensure their DLT registration number & Sender id is attached against every SMS request passed to the operators.
• In the phase 3 planned to go live on 7th Jan 2020 or earlier, Telecom operators want every business to ensure all their SMS formats / templates ( for OTP, Transactional & Promotional SMS ) are pre-registered on the telecom operator's DLT portal.
This also means, SMS sent to the operator from the unregistered entity / unregistered header / unregistered sms template would be discarded at the telecom operator's end.
General guidelines published by the telecom operators about SMS categories
Any message that contain OTP and requires to complete a banking transaction initiated by a bank or financial institution will only be considered as transactional messages. This is applicable to all banks (national/scheduled/private/govt or MNCs)
Examples of Transactional:-
• OTP message required for completing a net-banking transaction.
• OTP message required for completing credit/debit card transaction at a merchant location.
Any message arising out of customer’s action typically against a transaction/relationship with the enterprise that is not promotional will be considered as Service-Implicit message.
Examples of Service Implicit:-
• Confirmation messages of a Net-banking and credit/debit card transactions.
• Product purchase confirmation, delivery status etc. from e-comm websites
• Customer making payments through Payment Wallet over E-Commerce website/mobile app and an OTP is sent to complete the transaction.
• OTPs required for e-comm website, app logins, social media apps, authentication/verification links, and securities trading, demat account operations, KYC, e-wallet registration, etc.
• Periodic balance info, bill generation, bill dispatch, due date reminders, recharge confirmation (DTH, cable, prepaid electricity recharge, etc.)
• Delivery notifications, updates and periodic upgrades.
• Messages from retail stores related to bill, warranty.
• Messages from schools-attendance/transport alerts.
• Messages from hospitals/clinics/pharmacies/radiologists/pathologists about registration, appointment, discharge, reports.
• Confirmatory messages from app-based services.
• Govt/DOT/TRAI mandated messages.
• Service updates from car workshops, repair shops, gadgets service centers.
• Directory services like Justdial, yellow pages.
• Day-end/month-end settlement alerts to securities/demat account holders.
These are the messages which require explicit consent from customer, that has been verified directly from the recipient in robust and verifiable manner and recorded by consent registrar. Any service message which does not fall under service-implicit category.
Examples of Service Implicit:-
• Messages to the existing customers recommending or promoting their other products or services.
Any message (sent to non-customers or to general numbers or database) with an intention to promote or sell a product, goods or service. Service content mixed with promotional content is also treated as promotional. These messages will be sent to customers after performing the preferences and consent scrubbing function. Consent overrides preferences.