Non-banking finance companies have asked the Reserve Bank of India to clarify whether calls made to borrowers for overdue loan repayments must use TRAI’s dedicated 1600-series numbers, as lenders warn that customers are increasingly blocking such calls.
The issue was raised by NBFC chief executives and industry representatives during a meeting with RBI Deputy Governor S C Murmu, according to people familiar with the discussions.
The industry is not opposing the 1600 framework itself.
NBFCs broadly agree that promotional and sales calls should remain outside the dedicated series. Their concern is whether recovery calls — reminders about overdue instalments, repayment schedules or unpaid loans — legally fall within the category of “service calls”.
That distinction could determine how lenders are allowed to contact millions of borrowers.
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Why TRAI Created the 1600 Series
The Department of Telecommunications reserved the 1600 numbering series for service and transactional calls from government organisations and the Banking, Financial Services and Insurance sector.
The idea is simple: when a customer receives a call beginning with an authorised 1600 number, it should be easier to recognise that the caller belongs to a regulated financial institution rather than a fraudster impersonating a bank.
TRAI subsequently made adoption mandatory in phases.
Commercial banks had to migrate by January 1, 2026. Large NBFCs with assets above ₹5,000 crore, along with payments banks and small finance banks, had a February 1 deadline.
Other NBFCs, co-operative banks and regional rural banks were required to migrate by March 1.
TRAI has also made the rule strict.
Once the relevant deadline passed, covered entities could not make service or transactional calls from ordinary numbers, even if a customer had consented to receive the call.
The regulator says the framework is intended to curb spam and make financial impersonation scams harder.
What Are Service, Transactional and Recovery Calls?
The difference between these categories sounds technical, but it matters.
A promotional call tries to sell something — for example, offering a new personal loan or credit card.
A transactional call relates directly to a financial transaction, such as authentication or account activity.
A service call generally relates to an existing customer relationship, such as providing information or assistance connected with a product the customer already uses.
Recovery calls sit in a more awkward position.
If an NBFC calls a borrower because an EMI is overdue, the lender is not selling a new product. But the conversation is also more adversarial than an ordinary customer-service call.
NBFC representatives say TRAI’s current framework does not clearly spell out where such communication belongs.
That is why they are seeking RBI’s interpretation.
Borrowers Blocking 1600 Numbers Creates a Practical Problem
The industry says another issue has emerged after migration.
Some customers apparently block 1600-series calls, particularly when they receive repeated repayment reminders.
That creates a dilemma for lenders.
If a borrower does not answer or blocks the dedicated number, can the NBFC then call from an ordinary number?
Under the existing TRAI direction, that appears difficult because regulated entities are not supposed to initiate service or transactional calls from numbers outside the 1600 series after the mandatory adoption date.
Industry executives told ETBFSI that repeated blocking could undermine the very purpose of the system.
A dedicated caller identity helps consumers distinguish genuine financial institutions from scammers. But if that identity becomes associated in customers’ minds primarily with recovery calls, people may simply ignore it.
That could make legitimate communication harder.
Why This Is Also a Consumer Protection Issue
Recovery calls are already a sensitive area under RBI regulation.
Lenders and their recovery agents cannot use intimidation, harassment or threatening behaviour while collecting dues.
The debate over the 1600 series therefore involves two competing concerns.
Banks and NBFCs need a reliable way to contact borrowers about genuine overdue payments.
Customers, however, also need protection from aggressive recovery practices and from criminals pretending to be lenders.
The 1600-series system tries to solve the impersonation problem by giving regulated financial institutions a recognisable calling identity.
But it does not by itself resolve how often a lender may call, what recovery agents may say or when repeated contact becomes harassment.
Those questions continue to be governed by RBI’s separate customer-protection and recovery-agent rules.
TRAI Is Still Refining Its Calling Framework
The broader regulatory system is also evolving.
In March 2026, TRAI acknowledged during consultation that a single approach may not work equally well for every type of regulated entity, particularly smaller financial firms with limited customer bases. It discussed whether differentiated treatment may be appropriate depending on scale, sector and risk.
In August, TRAI also created a separate 1601 series for service and transactional calls by entities outside the BFSI and government sectors.
The direction of policy is therefore clear: regulators increasingly want legitimate institutional calls to come from identifiable number ranges rather than ordinary mobile numbers.
For NBFCs, the unresolved question is how loan recovery fits into that architecture.
The industry is not asking to bring sales calls back onto ordinary numbers.
It wants to know whether recovery communication is officially a service call, and whether any fallback is permitted when a borrower blocks the authorised 1600 number.
Until RBI or TRAI provides further clarification, lenders face the risk of either missing borrowers entirely or stepping outside the dedicated calling framework.
What this means for you: A genuine service or transaction call from a regulated bank or NBFC should increasingly come from an authorised 1600-series number. But a 1600 number does not give a lender the right to threaten or harass you during recovery; suspicious or abusive calls should still be independently verified and reported.
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