Running WhatsApp campaigns legally in India

SMS: DLT registration under TRAI's rules

TRAI's 2018 regulations set up a framework for unsolicited commercial communication built on distributed ledger technology — the DLT platforms the telecom operators run. In substance, an entity that wants to send commercial SMS registers on a DLT platform as a sender (TRAI's term is a principal entity), and the telemarketers that send on its behalf register too. The sender registers the headers its messages go out under and the content templates its messages follow, and TRAI runs a header information portal where anyone can check who a header belongs to.

The same framework gives customers a preference register. A subscriber can register a preference about the commercial communication they receive — the facility people call DND — and can complain through TRAI's app and portals when a message ignores it. Consent is recorded through the platform as well: a sender that wants to message people who have registered a preference needs their recorded consent to do so.

For a small business the practical sequence is: register your business as a sender on one of the operators' DLT platforms, register the header (the short sender id customers see), register each content template you will send, and only then send. Your SMS provider will refuse a message whose header or template is not registered, and the operators scrub campaigns against the preference register. TRAI's own UCC page is the place to read the regulation and its amendments; this guide states the framework in substance and does not add figures the page does not give.

Sources: TRAI: Unsolicited Commercial Communication (TCCCPR 2018)

WhatsApp: what Meta's Business Messaging Policy requires

Meta's WhatsApp Business Messaging Policy is short and direct about who you may contact. In its words, you may only contact people on WhatsApp if they have given you their mobile phone number or username and you have received opt-in permission from the recipient confirming that they wish to receive subsequent messages. Having a number is not consent; the policy asks for both.

The policy is equally direct about how a business starts a conversation: you may only initiate conversations using an approved Message Template, and Meta keeps the right to review, approve, pause and reject any Message Template at any time. A business can reply to a customer's message without a template inside the 24-hour customer service window, which opens and resets with each message the customer sends.

On stopping, the policy says a business must respect all requests — on or off WhatsApp — by a person to block, discontinue or otherwise opt out of communications, including removing that person from its contacts list. The policy also restricts what may be sold or promoted on the platform, with categories of prohibited and regulated goods and services; read the current version before you run a campaign in a regulated line of business.

Sources: Meta: WhatsApp Business Messaging Policy

Opt-in consent that holds up

Both rule books turn on consent, so the most valuable thing a campaign can own is a clear record of who agreed, to what, when and where. A tick box on your website or sign-up form, a line on the enquiry form at your counter, a question at billing, a reply of yes to a message that asked — each of these is an opt-in if it tells the customer what they will receive and they choose it.

Record the opt-in against the customer, not in a spreadsheet nobody opens: the date, the channel and the wording the customer saw. Keep the opt-in specific. Permission to receive appointment reminders is not permission to receive offers; if you want to send both, ask for both, in plain words. Do not buy or borrow lists: a number from a purchased list carries no consent you can show, and on WhatsApp it fails the policy's first test.

• Ask in writing, in the customer's language, and say what you will send and how often.
• Store the date, channel and wording of each opt-in on the customer's record.
• Ask separately for reminders and for offers; treat each as its own permission.
• Never message a purchased or shared list.

Template categories: marketing, utility and authentication

On the WhatsApp Business Platform every template you submit is placed in a category, and the category describes what the message is for. Marketing templates carry promotions, offers, announcements and invitations — anything whose purpose is to sell or to bring the customer back. Utility templates carry messages about a transaction or relationship the customer already has with you: an order update, an appointment confirmation, a payment receipt, a reminder about a service they bought. Authentication templates carry one-time passcodes.

The category matters for two reasons. The first is approval: a template written as a utility message that actually promotes something is rejected or re-categorised, and the campaign waits. The second is the customer's experience: a reminder that reads like an advertisement is the fastest way to earn an opt-out. Write each template for its category, keep variables for names, dates and amounts, and submit a few plainly worded versions rather than one clever one.

A practical rule for a campaign: if the message would make sense only to someone who bought from you, it is utility; if it would make sense to a stranger, it is marketing. Keep your marketing templates to the customers whose opt-in covers offers.

The 24-hour customer service window

The window is the part of the policy that changes how a team works day to day. When a customer messages you, a 24-hour customer service window opens, and inside it your team can reply freely — no template, any wording, as a conversation. Each new message from the customer resets the window. When the window closes, the only way to reach the customer again is an approved template.

Two habits follow. First, answer inside the window: a reply the next morning to a message sent last night is still inside it, but a reply three days later is a template. Second, think through the hand-off from campaign to conversation: a campaign template that invites a reply opens a window with every customer who answers, and that is where the real conversation — and the sale — happens. A shared inbox where the whole team sees those replies matters more than the campaign itself.

Sources: Meta: WhatsApp Business Messaging Policy

Opt-out handling

On WhatsApp, an opt-out can arrive in any words: stop, unsubscribe, don't message me, or a block. The policy's requirement is to respect all of them, on or off WhatsApp, and to remove the person from your contacts list for messaging. The practical standard is the same for SMS: a customer who registers a preference or asks you to stop has to stop receiving your campaigns, and the DLT scrubbing enforces it for you where a preference is registered.

Treat an opt-out as a change to the customer's record, not as a message to delete. Mark the customer, keep the date, and make sure every segment your campaigns go to excludes marked customers. Keep sending the messages the customer still wants — a receipt for something they bought is not a campaign — unless they asked for silence on everything, in which case give them silence.

• Recognise an opt-out in any wording and in any language your customers write in.
• Mark the customer's record the same day and keep the date.
• Exclude marked customers from every marketing segment before each send.
• Make it easy: tell customers how to stop in your marketing templates.

Sources: Meta: WhatsApp Business Messaging Policy · TRAI: Unsolicited Commercial Communication (TCCCPR 2018)

A campaign checklist

Run through this list before every send. It takes a few minutes and it is the difference between a campaign that reaches people and one that is refused by the provider, rejected by the platform, or remembered by customers for the wrong reason.

• SMS: sender, header and every content template registered on a DLT platform before the first message.
• WhatsApp: your own business number connected and every template approved before the campaign is scheduled.
• A written opt-in on each customer's record that covers the type of message you are sending.
• The right template category: marketing for offers, utility for reminders and updates, authentication for passcodes.
• A team ready to answer replies inside the 24-hour window, from one inbox.
• Opt-out words recognised, records marked, segments excluding them.
• A report after the send: delivered, read, replied, failed — per customer, not just a total.
• The customer's language: write the template the way the customer speaks.

How Selfeey handles this

Selfeey connects your own WhatsApp business number through MSG91 on every plan, with approved templates and a shared inbox where every conversation lands, so replies inside the window are answered by whoever is free. Templates and content live in one library, and single messages go out from the same number your customers already know.

On Business Suite and PRO Ultimate, WhatsApp, SMS and email campaigns go to your lists and segments, and the campaign report shows what happened to each message. Customers come in from Excel or Google Sheets, with their consent noted on the record, and the Customer 360 timeline shows every message, call and invoice for a customer on one page — which is where an opt-in, and an opt-out, belongs.

On PRO Ultimate, AI employees can reply in the inbox and prepare follow-ups, and the approvals queue holds what they prepare until you approve it. Nothing goes to a customer that you did not choose to send.

Questions