The TCCCPR Third Amendment, 2026 introduces a new A2P voice termination charge. For VNOs, the issue is not simply another five-paise cost—it raises important questions around NSO–VNO billing, enterprise pricing, AGR treatment, DLT visibility and competitive neutrality.

The Telecom Regulatory Authority of India notified the Telecom Commercial Communications Customer Preference (Third Amendment) Regulations, 2026 on 18 September 2026. The amendment significantly strengthens the framework governing Application-to-Person (A2P) voice calls, Unsolicited Commercial Communications (UCC), DLT-based enforcement and the obligations of Access Providers, including Virtual Network Operators. Telecom Regulatory Authority of India

One provision is particularly important for the VNO and enterprise-communications industry: a Terminating Access Provider (TAP) may charge an Originating Access Provider (OAP) up to ₹0.05 per minute for qualifying A2P calls.

For accuracy, this is ₹0.05 per minute—five paise per minute—not 0.05 paisa.

At first sight, five paise may appear insignificant. At enterprise calling volumes, however, its commercial impact can become material.

Why has TRAI introduced the five-paise charge?

The new charge should not be viewed as an ordinary wholesale termination tariff.

TRAI’s stated regulatory objective is to create an economic deterrent against misuse of inexpensive voice routes for bulk unsolicited A2P communication. The explanatory memorandum specifically states that the charge is intended as a deterrent against UCC rather than a cost-recovery mechanism.

This distinction matters.

The policy intent is not simply to increase the price of enterprise calling. It is intended to influence behaviour and encourage legitimate commercial communication to use the prescribed regulatory framework, numbering resources and DLT processes.

What exactly is an A2P call?

Under the amended framework, an A2P voice call broadly refers to a call initiated through an application, software system or automated platform without direct human dialling and delivered to an individual telecom subscriber. The definition includes technologies such as autodiallers, robocalls and prerecorded or artificial voice systems.

This means businesses operating in areas such as cloud telephony, outbound communication platforms, automated alerts, enterprise voice solutions and certain CPaaS environments must carefully classify their traffic.

This classification matters because not every enterprise voice call should automatically be assumed to attract the five-paise charge.

The charge is not applicable to every A2P call

The amendment provides an important exemption.

No A2P termination charge applies to calls made using the 140xx, 1600xx, 1601xx or another numbering series subsequently designated by TRAI for commercial communications, unless TRAI directs otherwise.

Therefore, the correct commercial question for a VNO is not simply:

“How many voice minutes do we carry?”

It is:

“How many of our minutes qualify as chargeable A2P traffic after applying the numbering-series and other regulatory exemptions?”

That distinction can materially alter the financial impact.

Why is the impact potentially greater for a VNO?

A traditional NSO owns the underlying network and has direct interconnection arrangements with other Access Providers.

A VNO operates differently.

Under the 2026 authorisation framework, a VNO connects its network through its parent Network Service Operator, and interconnection with other authorised telecom networks is undertaken through that parent NSO. Department of Telecommunications

Therefore, in a typical enterprise calling chain, the commercial flow may look like:

Enterprise / Sender → VNO → Parent NSO/OAP → Terminating Access Provider → Called Subscriber

If the terminating operator levies the permitted A2P charge, the cost may ultimately reach the VNO through its parent NSO, depending on the applicable NSO–VNO commercial arrangement.

This creates a new layer of cost that needs to be transparently separated from the existing wholesale voice charge.

Five paise becomes significant at scale

Assuming the maximum ₹0.05 charge applies to all the minutes in the example, the impact would be:

Chargeable A2P Minutes	Additional Cost at ₹0.05/min
1 million minutes/month	₹50,000/month
10 million minutes/month	₹5 lakh/month
50 million minutes/month	₹25 lakh/month
100 million minutes/month	₹50 lakh/month
100 million minutes/month for one year	₹6 crore/year

These figures are illustrative. Actual liability will depend on the percentage of traffic qualifying as A2P, applicable exempt numbering series and the amount actually charged by the TAP, because the Regulation permits a charge up to ₹0.05 rather than mandating ₹0.05 in every case.

The impact on VNO margins could be greater than the headline number suggests

Consider an enterprise calling product priced at ₹0.25 per minute.

A five-paise charge represents 20% of that retail price.

At ₹0.50 per minute, it represents 10%.

At ₹1 per minute, it represents 5%.

These percentages do not mean the enterprise necessarily pays those amounts—the VNO may absorb or partially pass through the charge—but they demonstrate why the effect should be assessed against the VNO’s margin rather than simply against its selling price.

For a business operating on narrow per-minute margins, five paise can consume a substantial portion of contribution margin.

That could affect CPaaS providers, cloud-telephony operators, telecalling businesses and enterprise communication providers relying upon VNO-based connectivity.

Should the VNO absorb the charge or pass it to the enterprise?

There are three possible commercial approaches.

A VNO may absorb the cost and protect its existing customer tariff. This provides price stability but directly reduces its margin.

Alternatively, it may pass the charge through to the enterprise customer as a separate A2P regulatory charge.

A third approach would be to restructure tariffs so that the regulatory cost is incorporated into the overall enterprise voice rate.

Each approach has consequences.

Large enterprise customers with high voice volumes are likely to examine the charge closely, particularly where competing NSOs also sell enterprise communication services directly.

This makes competitive neutrality particularly important.

TRAI has introduced an important protection against price squeeze

The amendment contains a safeguard that is highly relevant to smaller Access Providers and VNOs.

A TAP cannot charge another OAP an A2P termination charge exceeding the lowest tariff that the TAP offers to Senders or Telemarketers for whom it itself acts as the originating Access Provider.

This provision addresses a potentially serious competitive issue.

Consider an incumbent NSO that simultaneously:

terminates traffic from a VNO’s enterprise customer, while also competing directly for the same enterprise customer’s business.

Without an appropriate safeguard, a large operator could theoretically impose a high inter-operator cost while offering more favourable pricing to enterprises directly connected to its own network.

TRAI’s price-ceiling mechanism is intended to reduce this risk.

For the safeguard to work effectively, however, VNOs will require sufficient billing transparency to verify that the charge being passed through complies with the regulatory ceiling.

The AGR question is particularly important for VNOs

There is another issue that deserves careful regulatory clarification.

Under the Telecommunications (Authorisation for Provision of Principal Telecommunication Services) Rules, 2026, the annual authorisation fee is generally 8% of Adjusted Gross Revenue, subject to the applicable minimum fee conditions. Department of Telecommunications

For a VNO, the Rules allow certain payments to its parent NSO to be deducted while determining AGR. Specifically, charges paid under the NSO–VNO contract for bandwidth, leased circuits, call minutes and SMS necessary for providing telecommunications services can be excluded, subject to the prescribed contractual and payment-document requirements. Department of Telecommunications

This creates an important question:

Will the A2P charge passed by the parent NSO to the VNO qualify as a deductible call-minute/access charge for AGR purposes?

There appears to be a reasonable basis for such treatment where the amount is contractually identified, invoiced by the parent NSO and directly linked to chargeable call minutes.

However, the 2026 rules do not specifically name the Regulation 35A A2P charge.

VNOAI therefore believes explicit DoT clarification would be useful.

Why AGR treatment matters

Suppose a VNO pays its parent NSO ₹0.05 per minute and separately recovers exactly ₹0.05 from the enterprise customer.

If the amount paid to the parent NSO is accepted as a permissible AGR deduction, the regulatory impact of that pass-through may be substantially neutralised for authorisation-fee purposes, subject to proper accounting and documentation.

If the deduction were not permitted, the ₹0.05 recovered from the customer would increase telecom revenue while the corresponding regulatory cost may not reduce AGR.

At an 8% authorisation fee, 8% of ₹0.05 is ₹0.004 per minute—or 0.4 paisa per minute.

At very high volumes, even this secondary impact becomes material.

This is why the A2P charge should be addressed expressly in the NSO–VNO commercial agreement and revenue-accounting framework rather than merely appearing as an unexplained item on a wholesale invoice.

VNOs are not merely enterprise customers of NSOs

An equally important aspect of the Third Amendment goes beyond pricing.

TRAI has expressly recognised that VNOs fall within the definition of Access Providers under TCCCPR. At the same time, TRAI has acknowledged that VNOs cannot fulfil those regulatory responsibilities if the DLT systems remain exclusively controlled by their parent NSOs.

Accordingly, the amendment requires the concerned NSO to provide the VNO with a real-time digital interface with the DLT platform and relevant systems, enabling the VNO to fulfil its own regulatory obligations.

This is a significant regulatory recognition.

A VNO should therefore not be treated merely as an ordinary enterprise SIP/PRI customer when performing TCCCPR responsibilities.

What should VNOs do now?

For implementation to be commercially fair and operationally workable, VNOAI believes the following areas require attention:

• Charge only verified A2P minutes: NSOs should provide CDR-level reconciliation clearly distinguishing chargeable A2P traffic from exempt 140xx/1600xx/1601xx and other exempt traffic.
• No opaque NSO markup: the NSO–VNO agreement should clearly distinguish TRAI’s regulated inter-operator charge from the NSO’s existing wholesale tariff and any independently agreed service charge.
• AGR clarification from DoT: the treatment of the A2P charge paid by a VNO to its parent NSO should be expressly clarified for AGR deduction purposes.
• Competitive-neutrality transparency: VNOs need sufficient information to ensure that the amount charged does not exceed the lowest applicable tariff benchmark prescribed under Regulation 35A.
• DLT integration: the VNO must receive the real-time DLT functionality required to declare A2P traffic, map CLI resources, investigate complaints and act on UCC alerts.
• Standard NSO–VNO Code of Practice: billing, complaints, DLT responsibilities, A2P classification, blocking, appeals, evidence sharing and settlement of charges should form part of a standard regulatory-operational framework.

The real issue is not simply five paise

The purpose of TRAI’s amendment—reducing misuse of telecom networks for unsolicited commercial communication—is important and should be supported.

However, implementation must recognise the unique position of VNOs.

A VNO is simultaneously:

an Access Provider with regulatory responsibilities, a wholesale customer of its parent NSO, and often a competitor of that same NSO in the enterprise communications market.

The five-paise A2P charge therefore cannot be looked at in isolation.

Its impact depends on the complete chain:

Sender → VNO → Parent NSO/OAP → TAP → Subscriber

and on how the charge is identified, reconciled, passed through, deducted for AGR purposes and ultimately reflected in enterprise pricing.

VNOAI Perspective

The Third Amendment represents an important step because TRAI has expressly recognised VNOs as Access Providers and has required NSOs to provide them with the technical capability needed to perform TCCCPR obligations. The explanatory memorandum simultaneously confirms that VNOs have not been exempted from the A2P deterrent charge.

The next step should therefore be a clear and standardised NSO–VNO implementation framework.

The objective should be straightforward:

UCC deterrence should be effective, but legitimate VNO-based enterprise communications should not become commercially disadvantaged because of unclear charging, double recovery, lack of DLT visibility or inconsistent AGR treatment.

A transparent framework covering A2P classification, DLT access, charging, reconciliation, AGR treatment and competitive safeguards will protect consumers while enabling VNOs, CPaaS providers and enterprises to comply efficiently with the new regime.