5. Mobile number churn needs to be explicitly known and handled since it is a big source of complaints. This applies in the case of the opt-ins and transactional messages. Companies do not know when numbers churn. Therefore, what is needed is a Churned Numbers Database. When a number appears in this database, it will need to be deleted from all transactional message databases. This will ensure that the transaction database remains clean at all times.
6. Shutting down an SMS aggregator’s business for two years for just six violations is too small in an industry where a large aggregator sends billions of messages. My estimate is that about 200 million A2P SMSes are being sent in India daily. That is a total of 6 billion a month. Aggregators need to be given much more leeway. An alternative can be that if there are 100 proven complaints against an aggregator in a month, they should be fined and suspended for a month. If the complaints go to 1,000, then the aggregator be fined a higher amount and suspended for 3 months. And so on.