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Navigating TRAI Regulations for Call Centers in India

A Call Center operating out of India is offering a service over the telecommunications network. Such a service is mandated to follow some essential regulations and policies, which are usually collectively called ‘India toll compliance’ policies.

Regulatory Landscape

Telecommunications regulations and policies are primarily defined by the Department of Telecommunications (DoT) and regulated by the Telecom Regulatory Authority of India (TRAI).

DoT provides the Unified Access Service License (UASL), Cellular Mobile Telecommunications Service license (CMTS) and Unified License (UL) to telecommunication entities.

Additionally, for any entity providing non-telecom services over telephony infrastructure such as call centers, Other Service Provider (OSP) registration with financial guarantees is mandated.

Call Center Voice Infrastructure

Call Centers are typically dealing with a high volume of telephony calls to provide various types of services. To be able to do so, they typically have a mature voice infrastructure with various components like the private branch exchange (PBX), interactive voice response (IVR), proxies, call recorders, agent routing systems etc. Most of this infrastructure is using voice over IP (VoIP) for communication.

Also, the call centers are located in multiple locations across the country and are serving both domestic and international customers. A typical medium size call center service provider hosted on a single PBX, serves 7–10 enterprises (both domestic and international) and has over ten locations with thousands of agents.

The voice infrastructure needs to enable communication across these locations without violating the India toll compliance regulations

India toll compliance regulations

The OSP registration defines a set of policies that all call centers are expected to comply with. These regulations are defined to protect the revenue of the Indian telecommunications service providers (and by extension the government), and at the core define a few logical partitions –

  • The enterprise VoIP communication should be clearly separated from the public PSTN (public switched telephone network) traffic. There should be no mixing of the two, ensuring that there is no scope for any toll bypass. This is achieved through logical partitioning on the PBXs and other voice equipment.
  • The domestic service providers and the international service providers need to be completely separated, with no communication between the two. Additionally, the international service providers can’t access the domestic PSTN network.
  • A complete audit trail of all the calls needs to be maintained for a year.

These policies are then applied to the various possible scenarios that arise in a voice network, to define configurations that make the infrastructure compliant to the regulations.

For example,

  • Partitioning needs to be created on the conferencing bridges to ensure that a single conference does not contain a mix of PSTN callers and private enterprise callers.
  • Logical partitions in the PBX ensure that incoming PSTN calls are not sent over the VoIP network to another location thus avoiding national toll bypass. Additionally, any internal inter-location VoIP calls are not sent over the PSTN trunks.
  • Partitioning restrictions are also placed on various features like trunk-to-trunk transfers, enterprise mobility, softphone usage, call forwarding and special access permissions.

Most call centers are subject to a regular audit of their voice infrastructure and any violation of the India toll compliance regulations can result in large fines, and cancellation of their registration and ability to operate the call center.


Originally published by Sreekanth Nemani at techstory.in on July 12, 2017.

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