160 Number – Challenges from a Telecom Networking Perspective

Foreread: Aim of this blog is to provide a broad view on challenges/complexities faced by telecom operators in implementing 160 number series.

Background : Telecom Regulatory Authority of India (TRAI) has proposed use of 160 numbers for service and transactional calls in its recent regulations (TCCCPR). TRAI had already mandated use of 140 series numbers for promotional calls, however adoption has remained minimal. One of the reasons being exclusion of service / transactional voice call.

The 160 number regulation currently applies to Government and Financial entities regulated by RBI, SEBI, PFRDA, and IRDA and Broadly necessitated due to increased financial fraud over the years, growing need to avoid spam & consumer protection.

Needs of Banks and Financial Institutions

What used to be in-house, On-prem contact centers with agents working from one or few office locations, banks & financial institutions have evolved over the years to support their customers in many advanced ways. Few notable requirements apart from regular –  IVR, recording, deflection of calls etc. are:

1. Voice enablement of Field force Like Relationship Managers, Sales forces, branches etc.
2. Work from Home / Anywhere agents (Not just office agents).
3. Gen AI led, contextual conversation in voice calls for better CX, TCO and experience.
4. Business continuity / redundancy / seasonal and sudden spikes in volume.
5. Need for seamless migration, simple architecture both for internal agents and customers.

Banks and financial institutions do expect the telecom network / underlying network to scale up and deliver to the needs. Guidelines like “Other service provider” (OSP) have bridged a lot of ground, but needs of the end consumer and landscape is changing constantly – For eg. OTT players are also launching voice making voice calls truly multi-channel (PSTN, OTT voice – IP-IP calling). , what if consumer behavior shifts to OTT calling instead of PSTN calling ?

Of Course, Banks and financial institutions like to protect their consumers from fraudulent activities and spam. However, it will not be about just adopting 160 numbers. It will be all the above points and much more along with 160 numbers which helps them succeed !!

Now to the Main Topic of this Blog – Complexities for Telco Operators. 

Telecom in India is well regulated as there are multiple guidelines & regulations for the same. Enabling 160 number series should be firstly understood as “Enable 160 number series for service and transaction voice call while ensuring adherence to all other license conditions”. We will examine some broadly:

National Numbering Plan (NNP):

Number (Telecom identifier) itself is a limited resource. Current allocation of 160 series is at Circle / State level. Similar to Mobile numbers allocation. What this means is:

→ Limited number inventory

Each operator has only 1000 numbers per circle – some clients may have a centralized setup / agent pool and may need very few numbers. Others may have distributed 3rd party agencies. Couple this with concentration of contact centers / Customers specifically in cities like Mumbai, Bangalore, Delhi, Hyderabad, Tamilnadu etc. 

This may need Telco to build some channels / call volume to number ratio acceptable in general to all types of institutions.

Large allocation of numbers may still not yield the needful outcome of controlling fraud / spam. It is also seen in SMS DLT templates that misuse of templates from Telemarketers does happen for traffic mixing of international SMS to domestic SMS – violating the guidelines.

→ Impact on OSS (operations support systems) and BSS (business support systems)

The Number (or Pilot number) itself used to serve as a common identifier between Customer and Telco till now (Though account numbers etc. were available). 

This was used as a unique reference for operational issues like downtime, billing etc. If the same number is served across multiple locations – How should both customer and Telco refer during downtime / billing etc. Needs deliberation and detailing.

→ Lawful interception

For Mobile numbers – Law enforcement Agencies (LEA) expect information on lat/long apart from call details. For fixed / Wireline numbers – As the location is anyway fixed and delivery is done to the specific location the expectation is Telco BSS systems capture the delivery address. 

If there are multiple locations with the same number, and incidentally, the target number is 160 of the bank (not the end consumer’s mobile number who received the call), it further needs a slightly different approach/development to keep the response time to LEA in control. This is, though, a rare occurrence.

Coupling this with WFH and Internet Telephony scenarios where traditional telco + ISP networks participate in a call, identifying the location is even more complex but a largely regular deployment scenario.

→ National routing plan guidelines.

India had multiple licenses – AS, NLD, ILD, ISP license etc earlier. Efforts of license unification, uniformity and simplification under “Unified License” has definitely helped the growing needs. That said, there are different authorizations.

Simply put – Operators are required to handover calls to each other using POI (Point of interconnection) in the originating Legal Service area (LSA) or terminating LSA – Not in between (Partial carriage is not allowed). For fixed / Wireline line numbers the originating number itself acts as an identifier of LSA. For Mobile numbers, the MNP database acts as the source.

Should we now use 160 at national level, which is one number across states or Pan India – operators will not be able to easily identify, reconcile and adhere to national routing plans. This needs agreements among operators and TRAI to avoid any future disputes.

→ DLT platform and template validation

In its order, TRAI has recommended operators should enable the voice call service on DLT platform. DLT platform serves template registrations and also UCC complaints workflow. Operators are expected to deploy “AI based Tools / Techniques to detect & block suspicious keywords/URLs/Call Back numbers and phrases” more specifically for unregistered Telemarketers (UTM)

At Exotel, we are in a position to demonstrate this feature as we speak – Yes, it’s readily available with our Gen AIi based tools on top of the telco stack. The real question is, will the customers be ready to pay.

Both the Telecom industry and Banking / financial institutions – have fierce competition and look for ways and means to reduce TCO. If only the prices can be passed on to the consumer – an efficient, elegant solution can be achieved.

→ Inbound call perspective

Banks and financial institutions have requested for allowing inbound calls, as these are service / transactional calls. Considering the PE will get allocation of the number and the number is agnostic to TM / TSP and consideration of National Numbering plan (NNP), the telco’s are required to explore the call handling like Toll free or shortcode.

Toll free – Call control involves generally “Intelligent network (IN)”. This network provides origin based, load based, time based routing functionality. IN is generally a central element. Implementation is easier,  however, the cost of incoming calls increases. Currently India has gotten used to Rs.0/- for inbound calls.

Shortcode – Call routing generally involves call redirect (Simplicity sake – call divert) – This is generally achieved in the switches themself which are distributed. Configuring large numbers in this fashion may lead to routing table limitation.

Other Service Provider (OSP guidelines)

As we speak, DOT has allocated numbers as “Internet Telephony” and also allowed Mobile number series to be used for “Internet Telephony”. Essentially, though the UL / ULVNO license conditions allow internet telephony, the major contact centers (Who provide manpower) to these banks and financial institutions interpret only the OSP guidelines 

What this means is, as the Banks and financial institutions continue to seek flexible, PAN India based operations with ability to mix & match larger contact centers and smaller ones for additional manpower, the larger contact centers express concern on integrating PSTN on the internet even for “Internet telephony”. This again adds additional layers of cost, complexity in the network.

Others

• OTT apps like Truecaller / Device OS Google (Android) display spam status based on crowdsourcing or algorithms. At lLeast, for Truecaller – there is a way to still establish credibility / trust for the number using Truecaller verified calling. For Google there is no option. Our efforts with Google has led us to believe that Google has an algorithm which considers high calling volume as spam. With India’s mobile penetration and acceptance of new age banking and probably inability of algorithm to estimate / recorrect based on India’s call volume, customers / Telco have to battle the impact of unanswered calls
• Regulation mentions selective and careful allocation of 160 numbers to PEs who are sole proprietors – Will this require further elaboration for the Telecom companies to have uniform process across?.

At Exotel, we believe this is definitely a good starting point. We also believe with collaboration among telco’s, across industry stakeholders – Banks, financial institutions, RBI, SEBI, IRDA, and excellent leadership of TRAI, and DOT, we will surely achieve the outcome to arrest fraud and spam.

Ultimately, the law, regulations are to safeguard every citizen and national interest.

Creation of wealth for the country & Consumer and protecting the country & Consumer from fraud – both have to go hand in hand.