The Bar Council of India does not permit advertisement or solicitation by advocates in any form or manner. By accessing this website, www.khaitanco.com, you acknowledge and confirm that you are seeking information relating to Khaitan & Co of your own accord and that there has been no form of solicitation, advertisement or inducement by Khaitan & Co or its members. The content of this website is for informational purposes only and should not be interpreted as soliciting or advertisement. No material/information provided on this website should be construed as legal advice. Khaitan & Co shall not be liable for consequences of any action taken by relying on the material/information provided on this website. The contents of this website are the intellectual property of Khaitan & Co.

Please accept the above


See all results for ""

Redefining Calling Name Presentation: Enhancing Communication or Compromising Privacy?


On 23 February 2024, the Telecom Regulatory Authority of India (TRAI) issued recommendations on ‘Introduction of Calling Name Presentation (CNAP) Service in Indian Telecommunication Network’ (CNAP Recommendations) pursuant to stakeholder comments received in response to its consultation paper on this matter. By way of a background, the Department of Telecommunications (DoT) has been deliberating the introduction of CNAP service to provide users / called parties the ability to view the name of the calling party at call set up time while receiving incoming calls. Accordingly, DoT made a reference to TRAI to examine the feasibility of introducing CNAP as a supplementary service and issue its recommendations on this.

For context, in the present Indian telecom network, at the time of receiving an incoming call, the mobile/ landline numbers are displayed as Calling Line Identification (CLI). There is no mandate for presenting the name of the party making the call to the called party. The DoT noted that it was important to introduce this feature in order to enable the subscribers to view the name of the calling party. This would help subscribers make an informed decision while receiving an incoming call and identifying spam /calls from unknown sources.

Key features of the CNAP Recommendations


Introduction of CNAP supplementary service:

TRAI recommended the introduction of CNAP supplementary service in the Indian telecommunication network, emphasizing that all access service providers must offer CNAP service to their telecom subscribers upon their request. Specifically, the name provided by telephone subscribers in the Customer Application Form (CAF) was suggested to be utilized for the purpose of CNAP. In essence, CNAP service seeks to streamline the caller identification process while maintaining consistency with the information provided by the subscriber.


Technical model for implementation of CNAP:

TRAI took cognizance of the fact that a large part of the Indian telecom network is still based on circuit-switched (CS) core which may not be able to implement the CNAP service. In light of this, TRAI recommended changes in the technical model for implementation of the CNAP service. These changes include establishing and operating a database consisting of subscriber’s name against their telephone numbers, querying the Local Number Portability Database (LNPD) to identify the originating access service provider of the telephone call, etc. Accordingly, if the CNAP service is adopted by the DoT in the manner recommended by TRAI, telecom service providers (TSPs) will have to undertake the necessary technical modifications in the network to enable smooth integration of the CNAP service.


Trial and assessment for implementing CNAP:

In order to effectively introduce this service on pan-India basis in the Indian telecom network, TRAI has suggested conducting a trial and assessment of the service in one licensed service area (LSA) covering the subscriber base of each TSP within the LSA. This helps in ensuring a detailed understanding of the feasibility and potential challenges of implementing this service. Accordingly, necessary adjustments can be carried out to facilitate a successful rollout of the CNAP service across the entire country.


CNAP for commercial communications:

TRAI has also identified recommendations for the implementation of CNAP service in case of commercial communications. Particularly, TRAI recommended that in case of calls originating from 140-level numbers allocated to registered telemarketers and any other number series allocated for making transactional or service-related calls, the name of the subscriber entity should be presented to the called party. In order to do so, TRAI recommended that subscriber entities holding bulk and business connections should be given the option of presenting their ‘preferred name’ instead of the name appearing in the CAF. Such ‘preferred name’ could be the registered trademark name, trade name or any other unique name registered with the government, which can be corroborated by presenting the required documents. In this regard, TRAI has also sought that the DoT should formulate guidelines for documents to be provided by subscriber entities and to prevent any misuse of this facility.


Privacy considerations:

Introduction of the CNAP service could potentially open doors for concerns relating to privacy and data protection. For instance, CNAP service entails disclosure of personal information of a subscriber to the recipient, resulting in invasion of privacy particularly for callers who prefer to keep their identity private for security reasons or maintaining anonymity. Additionally, storage and transmission of caller information also exposes threat to potential vulnerabilities such as data breaches and unauthorised access which should be addressed through robust data protection measures. To address such privacy concerns and to enable control over an individual’s autonomy to manage their personal data, TRAI has suggested that the calling name of telecom subscribers who have availed the calling line identification restriction (CLIR) facility should not be presented to the called party.


TRAI has adopted a balanced approach vis-à-vis the CNAP service, redefining CLI in the telecom industry while also taking into account privacy considerations. The CNAP service is also likely to aid TRAI’s continuous efforts in curbing spam, malicious and fraudulent calls from unknown sources which has created a menace in the recent times. Notably, while various existing players are already offering spam and calling party name identification features through mobile applications, given that these applications rely on crowd-sourced data, the regulators in India sought a more trustworthy and reliable service to address this issue.

While these recommendations certainly aim to improve calling experience for telecom subscribers, it is pertinent to navigate these changes recognizing the importance of both safeguarding privacy and fostering innovation. While adjustments may be required, this evolution presents an opportunity for the industry to adapt and thrive in a more secure environment. It will be interesting to see whether the implementation of CNAP heralds a positive step towards a telecommunications landscape that balances user privacy with technological advancement.

  • Harsh Walia (Partner) and Sanjuktha Yermal (Associate)

For any queries please contact: editors@khaitanco.com

Harsh Walia (partners)

We have updated our Privacy Policy, which provides details of how we process your personal data and apply security measures. We will continue to communicate with you based on the information available with us. You may choose to unsubscribe from our communications at any time by clicking here.

For private circulation only

The contents of this email are for informational purposes only and for the reader’s personal non-commercial use. The views expressed are not the professional views of Khaitan & Co and do not constitute legal advice. The contents are intended, but not guaranteed, to be correct, complete, or up to date. Khaitan & Co disclaims all liability to any person for any loss or damage caused by errors or omissions, whether arising from negligence, accident or any other cause.

© 2021 Khaitan & Co. All rights reserved.


One Forbes
3rd & 4th Floors, No. 1
Dr. V. B. Gandhi Marg
Fort, Mumbai 400 001


119/65, First Floor
Dr Radhakrishnan Salai
Chennai 600 004,


Max Towers
7th & 8th Floors
Sector 16B, Noida
Gautam Buddh Nagar
201 301 India


Ocean Financial Centre
#37-02 10 Collyer
37th Floor Quay
Raffles Place 049315,