India calling rules: TRAI, DND and the DPDP Act

This page is for LumaKol customers whose teams call people in India. It covers TRAI’s rules on unsolicited commercial communication (the TCCCPR and the DND registry), the Digital Personal Data Protection Act, 2023, and call recording.

This page explains how LumaKol works and what it does and does not do. It is not legal advice. The rules depend on your sector, on why you are calling and on the consent you hold, and they change often, so take advice from your own lawyer before you rely on it.

• DND: a subscriber can block all commercial communication, or chosen categories of it, by registering a preference in the National Customer Preference Register, usually called DND.
• Number series: promotional calls are to come from 140-series numbers through a telemarketer registered with the telecom operators. Service and transactional calls from banks, insurers and other regulated financial entities are moving to the 1600 series.
• Unregistered senders: since August 2024, TRAI has directed operators to disconnect all the telecom resources of unregistered senders whose promotional calls draw complaints, and to blacklist them for up to two years (TRAI direction of 13 August 2024).
• Complaints: since the 2025 amendment, a person has 7 days to report an unwanted commercial call or message.
• Mixed content: a service or transactional call that also carries promotional content is treated as promotional.

• Calls after an enquiry: commercial calls based on a customer’s own enquiry are allowed only for seven days from that enquiry, and the enquiry must have been made in writing or by digital means and be kept in a verifiable form.
• Automated calls: calls started by an application or automated platform without direct human dialling, including autodialling, are application-to-person (A2P) calls. They must be declared to your telecom operator in advance, with the numbers used, or they are treated as unsolicited.
• Consent: consents you already hold count only if they were obtained in a verifiable way and are registered on the operators’ digital platform.
• Complaints: action against a sender can start at three complaints in ten days when the operator’s systems also flag the number.
• The 140, 1600 and 1601 series may not be flagged as suspected spam by caller-ID apps.

LumaKol is not a dialer platform. Every call is an ordinary mobile call from the agent’s own phone, on the SIM the agent chose as their work SIM, and the agent is there to talk when it connects. A call starts in one of three ways:

• The agent taps Call on a lead in the Android or iPhone app, or in their calling queue.
• The agent clicks Call on a lead in the web app, and the call rings out from their own phone.
• Auto-dial next lead, if the agent switches it on. It is off by default and is each agent’s own choice. After the agent logs the outcome of a call, the next lead in their queue is shown with a countdown of a few seconds, which the agent can change, and is dialled when it ends unless the agent cancels. It stops as soon as the agent leaves that screen, and it dials one lead at a time. Owners and admins can switch auto-dial off for the whole workspace (Settings → Calling → Allow auto-dial next lead); then every call starts with a tap.

The only numbers LumaKol ever calls are leads the customer has stored in its own workspace, and the call is placed through the phone's own dialer. LumaKol does not generate numbers to call, does not dial several numbers at once or ahead of an available agent, does not play artificial or prerecorded voice messages, and does not leave voicemails. Text messages and WhatsApp messages from a lead open in the agent’s own messaging app for the agent to send; LumaKol does not send them.

Auto-dial next lead starts the next call after a countdown, without the agent tapping. Under the September 2026 amendment, calls started by an application without direct human dialling are A2P calls that must be declared to your telecom operator in advance. Unless you have made that declaration, switch auto-dial off for the workspace (Settings → Calling → Allow auto-dial next lead) so that every call starts with a tap, and ask your lawyer.

• It does not check numbers against the DND registry, and it does not tell you whether a number is registered.
• It is not a telemarketer platform. It does not place calls from 140-series or 1600-series numbers; every call comes from an agent’s own SIM.
• It does not register you, your headers or your templates on the operators’ DLT platform. SMS and WhatsApp templates open in the agent’s own apps for the agent to send.
• It does not collect, verify or store proof of consent on your behalf, beyond what your team records on the lead.
• It does not scrub the lists you import. The do-not-call block follows the lead record: if a lead who opted out is deleted and the number is imported again later, the new lead is not blocked. Keep opted-out leads instead of deleting them.
• The calling-hours, do-not-call and attempt checks are made by the LumaKol mobile apps. A call an agent dials directly in the phone’s own dialer is not checked.

Screening lists, holding consent, choosing whom to call and why, and using a registered telemarketer for promotional campaigns remain your responsibility.

• Call people who asked to hear from you: enquiries, existing customers and people who gave consent. Keep cold promotional campaigns off your agents’ mobile numbers.
• Call enquiries within seven days of the enquiry, and get the person’s consent before calling them after that.
• Keep Auto-dial next lead switched off for the workspace unless you have declared A2P calling to your telecom operator.
• If you run promotional campaigns, use a registered telemarketer and 140-series numbers for them.
• Screen bought or cold lists against DND before you import them, and keep the record of the screening.
• Record consent on the lead: the source, the date and how the person asked to be contacted. Custom fields work well for this.
• Keep “Block calls to leads who asked not to be contacted” switched on, and have agents log “Requested no contact” the moment someone asks.
• Set calling hours and days that suit the people you call, and an attempt limit that does not read as harassment.
• Tell people when a call may be recorded, and limit who can listen in Settings → Privacy.
• Collect only the fields your sales process needs, and be ready to correct or delete a person’s record when they ask.

If you have a question about how a LumaKol feature works, write to support@lumakol.com. For questions about your legal obligations, speak to your own lawyer or read TRAI’s regulations: we cannot tell you whether a particular call is lawful.