On May 13, 2026, Exempt Resolution No. 900 of 2026 (“Resolution 900”), issued by the Undersecretariat of Telecommunications (“Subtel”), was published in the Official Gazette. The resolution amends the numbering regime applicable to mass communications and expressly incorporates an exception for extrajudicial collection communications.

This amendment follows the regulatory framework introduced by Exempt Resolution No. 286 of 2025, through which Subtel amended Exempt Resolution No. 1,319 of 2004 by incorporating two new categories of complementary services corresponding to: (i) unsolicited mass communications and (ii) solicited mass communications, assigning them the numbering blocks 809 XXX XXX and 600 XXX XXXX, respectively.

Subsequently, on March 5, 2026, the Supreme Court, in case No. 41,033-2025, upheld an economic protection action filed by the Asociación Gremial de la Industria del Retail Financiero A.G., invalidating Ordinary Official Letter No. 11,269 of 2025 issued by Subtel, through which it had interpreted that extrajudicial collection calls were subject to the aforementioned numbering blocks.

In its ruling, the Supreme Court held that:

• Extrajudicial telephone collection does not constitute a complementary telecommunications service; and
• Consequently, such communications are not subject to the 600 and/or 809 numbering regimes.

In compliance with this ruling, Resolution 900 amends Exempt Resolution No. 1,206 of 2025 also issued by Subtel —which establishes exceptions to the numbering regime— by expressly incorporating a new exception for:

“Communications whose objective is extrajudicial collection”.

As a result of this amendment:

• Extrajudicial collection communications are formally excluded from the category of mass communications; and
• Consequently, such communications are not required to use the 600 and/or 809 prefixes.