How Plivo handles Unsolicited Commercial Communication (UCC) complaints for Indian voice numbers, and what you need to do.
Applies to: India voice numbers (landline series, 160 series) · Regulation: TRAI TCCCPR (Second Amendment) Regulations, 2025
Overview
If someone receives a commercial call they didn’t consent to, they can file a UCC complaint with their telecom provider. TRAI — India’s telecom regulator — requires Plivo to investigate these complaints and take action when they are valid.
This page explains how the complaint process works, what you need to do when a complaint is filed against your calls, and what happens if you don’t respond in time.
TRAI Definition — UCC: “Unsolicited Commercial Communication or UCC” means any commercial communication that is neither as per the consent nor the registered preferences of the recipient. Transactional and service voice calls are explicitly excluded — but only when made from the correct number series.Source: TRAI TCCCPR (Second Amendment) Regulations, 2025 — Regulation 2(bw)
Number series matter. TRAI mandates specific number series for specific call types — landline series (e.g., 022, 080) for non-BFSI service and transactional calls, and 160 series for BFSI service and transactional calls. Using the wrong series is itself a violation — complaints arising from such calls are treated as UCC regardless of consent. See India Calling Regulations for the full breakdown of permitted uses per series.
How Does Plivo Notify Me About a UCC Complaint?
If Plivo receives a UCC complaint and the call is traced to a number rented on your account, you receive a series of email notifications at your registered account email and any additional recipients configured in the Plivo Console.
| Timeline | Email Sent | Trigger |
|---|
| Day 0 | Initial complaint notification | Plivo receives and validates UCC complaint |
| Day 3 | Reminder | No valid proof submitted yet |
| Day 5 | Final reminder | No valid proof submitted yet — last chance before action |
| Day 6+ | Compliance action notice | Proof deadline expired — compliance ID blocked |
Email Recipients
All UCC notifications are sent to:
Keep your notification list current. Not receiving an email notification does not exempt you from your compliance obligations or the consequences of missing the 5-day proof submission window.
What Do I Need to Do When I Receive a Complaint?
You are required to take the following actions within 5 business days of receiving the complaint notification from Plivo.
1. Submit Consent Proof
You must provide documented evidence that the complainant gave valid prior consent to receive calls from your business.
Your proof must contain all three of the following:
| Required Element | Details |
|---|
| Business logo | The logo or identity of the business entity that made the call, to verify the caller’s identity on the DLT platform |
| Date of consent | The date the recipient gave explicit consent to receive calls. Must be within the last 6 months from the complaint date. |
| Complainant’s phone number | The exact number of the person who filed the complaint, confirming consent was obtained for that specific number |
6-month consent validity window. Consent acquired more than 6 months before the complaint date will not be accepted. Ensure your consent collection system records timestamps accurately.
If Your Proof Is Rejected
If the submitted proof is incomplete, expired, or does not meet Plivo’s review criteria:
- Plivo sends you an email with the reason for rejection.
- You must resubmit valid proof within the same 5-day window.
- If no valid proof is submitted before the deadline, compliance action proceeds as described below.
2. Remove the Complainant from Your Calling List
Regardless of whether your proof is accepted or rejected, immediately remove the complainant’s phone number from your outbound calling list.
Do not call again. Continuing to call a person who has filed a UCC complaint is itself a violation under TRAI regulations, irrespective of whether you hold valid consent documentation.
What Happens If I Don’t Submit Valid Proof?
TRAI prescribes a structured escalation framework, which Plivo is obligated to enforce as your OAP. Consequences are tied to your compliance ID, not your overall Plivo account.
No compliance ID mapped to your number? If a UCC complaint is received against a number that has no compliance ID mapped to it, the complaint will be counted against the billing entity — leading to compliance actions against your entire business, not just a single number.
| Scenario | Trigger | Consequence |
|---|
| Single complaint — no proof in 5 days | 1 valid UCC complaint; proof not submitted within 5 business days | Compliance ID blocked for 15 days. Submitting valid proof during this window lifts the block. |
| First violation | 5 or more unique recipient complaints within any rolling 10-day window | Compliance ID suspended for 15 days. Submit valid proofs within 15 days — if accepted, violation is waived. If not, counts as 1st violation. |
| Second violation | A second instance of 5+ complaints in 10 days after 1st violation | TRAI blacklisting. All telecom resources barred for 1 year across all providers in India. No new services can be obtained from any operator. |
Single Complaint — No Proof in 5 Days
If a valid UCC complaint is received and you fail to submit proof within 5 business days, Plivo blocks your compliance ID:
- All outgoing calls from your compliance ID are suspended.
- The block is in place for 15 days.
- You may submit valid proof during these 15 days to lift the block.
- If no valid proof is received within the 15-day window, the block may be made permanent pending further review.
First Violation — 5 or More Complaints in 10 Days
As per TRAI Regulation 25(4)(f)(i), if Plivo receives complaints from 5 or more unique recipients within any rolling 10-day window, TRAI mandates immediate suspension. Plivo:
- Suspends your compliance ID immediately upon detection.
- Issues a formal notice giving you an opportunity to submit representations and proofs.
- Reviews submitted proofs within 5 business days of receiving your representation.
- If all proofs are valid: the violation is waived — it does not count against your record.
- If proofs are invalid or not submitted: this counts as the 1st violation. Your compliance ID is barred for 15 days.
Second Violation — TRAI Blacklisting
If a second instance of 5+ complaints within a 10-day window occurs after the first confirmed violation, TRAI mandates the following under Regulation 25(4)(f)(i)(B):
- All telecom resources — including PRI/SIP trunks — are disconnected by all Access Providers for 1 year.
- The sender is blacklisted on the DLT platform. No new telecom resources can be provisioned by any provider during this period.
- All devices used for making UCC may also be blocked across all Access Providers for 1 year.
TRAI blacklisting applies across all operators in India. A blacklisted business cannot obtain telecom services from any operator in India for the duration of the blacklisting period — not just Plivo.
Right to Represent
You may file a representation with Plivo against any action taken at the first or second violation stage. Plivo is required to decide on the representation within 7 business days. You may also appeal to TRAI directly under Regulation 29 of the TCCCPR Regulations.
