DLT is a deeply flawed solution...

DLT or Distributed Ledger Technology is a block-chain based registration system. According to TRAI (Telecom Regulatory Authority of India), all companies who send SMSes have to be registered in the DLT platform.  Its stated goal is to control the SMS spam from various marketing firms and perhaps provide more secure communications.

Unfortunately, not only is it onerous and difficult to manage, it destroys Innovation and will set Indian companies back in their ability to create better products. Here’s why:

1.     It is completely blocking certain innovations that we are currently working on. For example, creating conversational bots that respond to customers with customized SMS responses to their queries. These responses use AI to make it appear that a person is replying. No human response can be faster plus there are other advantages of using AI that I am sure are well knows. However, by requiring SMSes to conform to templates, we cannot even think of building such products – products that will help us beat international competition.

2.     DLT is obstructing our ability to innovate by making it time-consuming and difficult to change our messages. It takes several days to get a message approved, since it is a multi-step process to get approvals first from the DLT site at the Telecom and then at the SMS provider. We often add features using Agile Programming Methods (used by most modern programming teams) where we deploy in short (one to two week) sprints, get feedback from users and modify messages to reflect the changes. This is not practical to do if we have to make fresh templates after every iteration.

3.     Our Delivery Persons and customers often communicate with each other – to give directions or to negotiate timing of Delivery. We have implemented a feature that allows this communication to occur through Chat. This feature allows us to send chat messages from the Delivery Person’s App to the Customer’s App. However, when a customer has not downloaded our App, we send the messages through our backend and thence through the SMS system. This allows Customers to communicate safely – that is without exposing their number to the Delivery Person and vice versa. We cannot possibly provide this feature via templates because these are individual messages and therefore cannot provide safety to our customers any more.

4.     We create IoT based devices which communicate with our servers to update other devices and apps. Although most of the communication is over the Internet, SMS messages can be used when the Internet is down or when speed of communication is important. DLT will now require us abandon some features – most notably the ability to send encrypted information directly to other devices or maintenance teams.

5.     Our Business to Business customers all require custom messages. In particular, we work with several banks and their risk mitigation and legal departments often have stringent requirements on the content of the messages we send out. Each of these businesses has anything from 4-7 custom messages each. Right now we have only about ten B2B customers. Imagine when we have hundreds of such customers (which we hope to achieve soon) – we will have to make hundreds if not thousands of templates and that many new templates each time we make a change or add a feature.

6.     All DLT templates need to be saved and then approved at the telecom provider (such as Airtel or VI) and then again saved and then approved at the SMS service provider. As a business we need to have the ability to switch providers/vendors when we find better service or better pricing. Imagine how difficult it would be to move these hundreds or perhaps thousands of templates from one SMS provider to another!

7.     It doesn’t solve the problem that I understand it is supposed to – to control Spam. Marketing messages are still allowed, and the volume of unwanted solicitations (in other words, Spam) I am receiving daily has not changed. As a consumer, I am unable to remove myself from Spam message lists or even call lists. At best, I can block that number or Header Code. Unlike email where you can click on an unsubscribe link, SMS messages don’t have that feature. Perhaps requiring that will better control Spam than the current system.

There are several other solutions possible, and as an awarded innovator, I would humbly state that I would be qualified and willing to help the government develop such solutions. I am sure that there are many others like me who would be willing to find better solutions.  

One such solution would be to develop an India centric “Bharat SMS APP”. This app could have features to automatically block and/or report spam messages. These reports could be consolidated at the Government and the entities who have spammed could be penalized starting with the most egregious offenders. This could be highly automated and could use AI to analyze the messages and sending patterns.

An additional step that the government could take is to allow DIPP certified startups like us to be use the SMS systems without the restrictive burden of using templates. Any company certified by DIPP is certainly not likely to rely on Spam for growth. Also, since the number of such startups is small, monitoring becomes far easier and abuse, if at all it happens, can be quickly identified and stopped.

There are many such solutions, and if the Government can engage with Startups as well as large companies, we can together create a world-beating solution.