A promotional message can often reach a customer long after the interaction in which they may have given permission to receive it. That consent may have been given while opening an account, registering for a service, downloading an application, or completing a form. But as time passes, customer preferences can change. People may develop new interests, discontinue products, change service providers, or simply decide they no longer wish to hear from a particular company. However, communication can continue even when that earlier permission may no longer reflect what the customer wants today.

Consent, therefore, should not be considered permanent. This raises an important question: should consent provided once remain valid for promotional communication indefinitely, without any consideration of the customer’s current intent?

This question sits at the heart of India’s continuing efforts to address spam. Over the years, India has steadily strengthened the regulatory architecture governing commercial communication. From the Telecom Commercial Communications Customer Preference Regulations (TCCCPR) and Distributed Ledger Technology (DLT) to entity registration, template verification, and the Digital Consent Acquisition (DCA) framework, several layers of regulation have come together to create a comprehensive anti-spam ecosystem.

The regulatory framework is already there. The challenge now is to ensure that the consent is enforced at the most appropriate point in the messaging process. Under the proposed DCA framework, consent acquisition, recording, and validation of consent largely happen upstream, with Originating Access Providers (OAPs) and other participants taking on a central role in onboarding enterprises, maintaining consent records, and enabling message origination.

The TAP is the operater that faces the subscriber. It is responsible for managing customer preferences, spam reports and complaints, and customer trust. When unwanted communication reaches a subscriber, it is the TAP they turn to for resolution.

Yet, despite this direct customer relationship, the TAP does not control the consent-verification mechanism that determines whether a commercial message is delivered. This creates a disconnect: the entities responsible for consent can remain removed from the customer relationship, while the operator expected to protect the customer has limited authority over the records governing message delivery.

The consequences of this separation are visible in the DLT ecosystem. Of the 32,095 blacklisted entities currently on the platform, almost 87 percent are linked to only two OAP-exclusive telecom providers, with one accounting for approximately 53 percent and another for around 34 percent. In the quarter ending March 2026, a single operator accounted for nearly 40 percent of all blacklisted templates. These figures point to a structural concern: when consent verification sits away from the customer relationship, enforcement can depend on records that may not fully reflect current subscriber preferences.

A TAP-led approach to consent management should therefore be considered under a TAP-led DCA framework. The subscriber’s telecom operator would capture, validate, store, and enforce consent, checking it against the customer’s present preferences and consent status before allowing a commercial message to reach the subscriber. This would make consent a more responsive mechanism, rather than relying solely on what was permitted during an earlier interaction.

This model would offer several benefits.

First, it would bring responsibility and decision-making together. The operator that manages the customer relationship would also be empowered to determine whether a commercial message should reach them, removing the current gap between consent management and customer protection.

Second, it would make consent responsive to change. Revocations, complaints, changing preferences, and ongoing engagement could be considered at the point of verification, allowing a customer’s current choice to inform message delivery.

Third, it would enhance data governance. Sensitive consent information could be kept within the ecosystem closest to the subscriber, reducing unnecessary replication across intermediaries and allowing for stronger confidentiality and oversight.

Fourth, it would enhance operational agility for customer-facing operators. New user controls, security measures, and protection mechanisms could be introduced more quickly, while common industry standards preserve interoperability across the ecosystem.

Most importantly, a TAP-led model would bring consent closer to both the customer and the point of delivery. India has already built a strong foundation to tackle spam; the next step is to ensure that the systems governing commercial communication are equally responsive to customer choice.

As digital communication grows, customer trust will depend on giving subscribers greater control over what reaches them. Meaningful consent should therefore be reflected not only in what was agreed to in the past but also in the customer’s choice at the point of delivery.

(DISCLAIMER: Views expressed are the author’s personal.)

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