One common problem with anti-spam controls that focus on business channels like A2P SMS is that scumbags just shift their efforts towards spamming the public using person-to-person (P2P) channels instead. So the Telecom Regulatory Authority of India (TRAI) is considering a refreshingly straightforward way of tackling P2P spam that will not impact most ordinary users.
Per TRAI’s figures, there were under 140,000 complaints during 2023 about spam from registered telemarketers. This represents a two-thirds fall from the peak of 428,290 complaints in 2021, and is credited to new anti-spam rules that were introduced in the meantime and which leverage the national anti-spam distributed ledger. However, complaints about unregistered marketing through P2P voice and messaging originating with 10-digit mobile numbers has continued to rise, and exceeded 1.2 million last year. Comms providers are supposed to warn phone users about excessive use related to telemarketing, and to then impose usage caps or disconnect users who are guilty of repeat violations. The flaw in this approach is that it is too slow to be effective, so one proposed remedy is to end the practice of offering retail customers allowances that include unlimited calls or large numbers of SMS messages. In other words, the cost of making an additional call or sending an additional SMS would rise dramatically at a certain point associated with unusually high levels of usage.
TRAI also proposes mandatory monitoring of usage patterns for any customer who makes more than 50 outgoing calls or sends more than 50 outgoing SMS messages per day. This monitoring regime would look for common indicators of automated spam, such as the use of different B-numbers for each outgoing communication, calls having an average duration of under 10 seconds, or a highly skewed ratio between outgoing and incoming communication.
The anti-spam consultation covers too many other interesting proposals to address them all here, but they include:
- the use of honeypots;
- enhanced traceability of comms to their origin;
- phone users needing to give explicit consent before they can receive any robocalls;
- tight deadlines for investigating complaints about spam; and
- new penalties for non-compliance.
TRAI’s consultation document is available here. September 25 is the deadline for the first round of responses, and October 9 is the deadline for follow-on comments.



