Thinking of AI calls for your clinic? Read TRAI's new rules first.

By Jaideep Badal · 28 September 2026 · Updated 14 October 2026 · 7 min read

Every clinic owner is being pitched an "AI receptionist" right now. Some of these tools only answer calls. Others also call patients: reminders, follow-ups, "we haven't seen you in a while" campaigns.

The second kind now falls under strict telecom rules. On 18 September 2026, TRAI (India's telecom regulator) amended its anti-spam regulations to cover automated calls, robocalls and artificial or pre-recorded voices. If your vendor gets this wrong, the number your clinic calls from can be barred or disconnected.

Here is what a clinic needs to know.

What TRAI now treats as an automated call

TRAI defines an Application-to-Person (A2P) call as a voice call started by an application, software system or automated platform without direct human dialling. An AI voice agent that calls patients is exactly this.

The new rules say:

• Declare it first. Anyone making automated calls must tell their telecom provider in advance and list the numbers the calls will come from.
• Undeclared calls count as spam. They are treated as unsolicited commercial communication.
• Penalties escalate. KYC re-verification, physical verification, barring of outgoing calls, and disconnection of telecom resources for repeat violations.
• A small per-minute charge. Up to 5 paise per minute on automated calls, except those made from TRAI's designated series (140, 1600, 1601).

How long can a clinic follow up on an enquiry?

This is the change most clinics will feel first, and it has nothing to do with AI.

Say someone messages your clinic on a Sunday: "How much is a knee physio session?" Under the amended rules, that enquiry lets you send them commercial communication for seven days from the date of the enquiry. After that, the enquiry alone is no longer enough. You need their consent to keep contacting them.

Two conditions come with it:

• The enquiry has to be in writing or through digital means. A WhatsApp message, a website form, an email.
• You have to keep it in a verifiable form. If someone complains, you should be able to show when and how they asked.

In practice, this means two things for a front desk:

1. Reply fast and follow up within the week. An enquiry that sits in a register for ten days and then gets a "special offer" call is exactly what the rules now target. We wrote more on this in why clinics have a follow-up problem, not a no-show problem.
2. Ask for consent while the window is open. If the person wants to hear from you later, about a follow-up session or a health camp, record that clearly.

Patients who are already being treated at your clinic are a different situation. Their appointment reminders are service calls, covered by the number series below.

Which number series fits which call

Promotional calls also need the patient's consent and must respect the national Do Not Disturb (DND) registry. Using a normal mobile number for automated calls is one of the most common violations, and telecom operators now use AI to detect it.

When do the new rules start?

TRAI issued the amendment on 18 September 2026. It doesn't switch on all at once. Most provisions come into force 30 days after the rules are published in the Gazette. A few take 60 days, and the bigger system changes, like operators sharing AI-flagged spam numbers with each other, take 90 days.

For a clinic, the safe reading is simple: treat the rules as live from late October 2026, and set up your follow-up process now rather than after a complaint.

What happens if a patient complains?

Patients can report unwanted calls or messages by calling or sending an SMS to 1909, or through the TRAI DND app. If they aren't happy with how the complaint was handled, they can now appeal within 15 days.

On the other side, telecom operators no longer wait only for complaints. Their AI systems flag suspicious numbers on their own. If several numbers linked to the same sender get flagged within ten days, the operator can re-verify the sender's KYC, bar outgoing calls, and for repeat cases disconnect the numbers. Losing the clinic's main number would hurt far more than any fine.

Answering calls is different from making them

These rules are about calls your system makes. An AI that answers when a patient calls your clinic is not an automated outgoing call.

That doesn't mean anything goes. Two things still apply:

• Tell callers they're talking to an AI. It's honest, it builds trust, and regulators are moving in this direction.
• Treat call data as patient data. Recordings and transcripts that mention symptoms or treatment are covered by India's data protection law. See Is your clinic's WhatsApp ready for India's new data protection law?

For most clinics, the safest first step is to answer every call and follow up on WhatsApp, not to start calling patients. We compared the options in AI receptionist vs human receptionist.

6 questions to ask any AI calling vendor

1. Is the calling number declared to the telecom provider for automated calls?
2. Do reminder calls go out from a 1600-series number, and promotional calls from a 140-series number?
3. Is the outgoing list checked against DND before every promotional campaign?
4. Does the agent say it is an AI at the start of the call?
5. Where are call recordings and transcripts stored, and who can access them?
6. Will you sign a data processing agreement with my clinic?

If a vendor can't answer the first two clearly, don't let them call your patients.

Where Tevio fits

We help clinics decide what to automate and in what order, and which vendors are safe to use. Before any AI calls a patient, we check the setup against these rules. We also help front desks set up a simple enquiry log, so every enquiry gets a reply inside the seven-day window and there's a record if anyone asks.

Frequently asked questions

Can my clinic still call someone who enquired two weeks ago?

Not on the strength of the enquiry alone. An enquiry allows commercial communication for seven days from the date it was made. After that, you need the person's consent.

Does a phone enquiry count for the seven-day window?

The rules say the enquiry must be made in writing or through digital means, and kept in a verifiable form. WhatsApp messages, website forms and emails fit this clearly. If most of your enquiries come by phone, ask the caller to send a WhatsApp message or fill a short form, so you have a record.

Are appointment reminders to existing patients affected?

Reminders about a patient's own care are service calls. If they are automated, they must be declared to your telecom provider and should go out from a 1600-series number, not a regular mobile number.

Is an AI receptionist that answers calls covered by these rules?

No. The A2P rules cover calls your system makes. An AI that answers incoming calls is not an automated outgoing call, though call recordings are still patient data under India's data protection law.

When do the new TRAI rules take effect?

Most provisions come into force 30 days after publication in the Gazette, with some at 60 and 90 days. Clinics should treat them as live from late October 2026.

This article explains the rules in plain words. It is not legal advice. Updated on 14 October 2026 to add the seven-day enquiry rule, the start dates and the complaint process.

Sources: 1. TRAI: Telecom Commercial Communications Customer Preference (Third Amendment) Regulations, 2026 · 2. TRAI press release, 18 September 2026 · 3. PIB: TRAI strengthens framework for curbing unsolicited commercial communications