Exempt Resolution No. 900 of 2026 (RE900) of the Undersecretariat of Telecommunications (Subtel), published in the Official Gazette on May 13, 2026, closes a regulatory debate of more than a year: telephone extrajudicial debt collection is not a mass communication and is not subject to the numbering regime that requires the use of the 600 or 809 blocks. The decision complies with the Supreme Court ruling in Case No. 41,033-2025, of March 5, 2026.
If your company carries out or contracts telephone extrajudicial debt collection services, this change eliminates a regulatory obligation that many applied as a precaution. RE900 expressly records that this scheme does not apply to you.
What changed
The origin of the controversy is Subtel's Exempt Resolution No. 286 of 2025, which amended Exempt Resolution No. 1,319 of 2004 —the base rule for numbering in Chilean telecommunications— to incorporate two new categories of supplementary services: unsolicited mass communications, assigned to the 809 XXX XXX block, and solicited mass communications, assigned to the 600 XXX XXXX block.
Subtel later extended that regime to debt collection. Through Official Ordinance No. 11,269 of 2025, the Undersecretariat interpreted that extrajudicial collection calls fell within those categories and had to operate under the 600 or 809 prefixes as applicable. The ordinance did not have regulatory rank, but in practice it generated compliance pressure on the market.
The Financial Retail Industry Trade Association A.G. challenged that interpretation through an economic protection action (recurso de amparo económico). On March 5, 2026, the Supreme Court, hearing Case No. 41,033-2025, granted the action and set aside Official Ordinance No. 11,269 of 2025. The reasoning was precise: telephone extrajudicial debt collection does not constitute a supplementary telecommunications service and, consequently, the 600 or 809 numbering regime does not apply to it.
In compliance with that ruling, RE900 incorporated an express exception into Exempt Resolution No. 1,206 of 2025 —which lists the acts excluded from the mass regime—: "Communications whose purpose is extrajudicial debt collection". Without conditions. Without deferred entry into force.
What it may mean for your company
RE900 matters if you are in one of these groups: you operate your own collection call centers or campaigns, you contract collection services from third parties, or you provide communications infrastructure to companies that collect debts. In all three cases, the obligation to use the 600 or 809 block for those activities disappears.
The practical effect is not trivial. The 600 and 809 numbering blocks have infrastructure costs: line enablement, contracting with authorized operators, platform adaptation. Some companies had already adjusted their systems in response to Ordinance No. 11,269. RE900 eliminates the regulatory basis for that requirement, which opens the possibility of reviewing those commitments and costs.
There is another angle. The 600/809 regime also has an impact on the recipient's perception: 809 numbers are associated with unsolicited mass calls, which affects answer rates and, in some cases, generates rejection before the conversation even begins. The exclusion from the regime allows a return to more neutral numbering for collection management.
But the protection has a perimeter. RE900 covers exclusively communications whose purpose is extrajudicial debt collection. If your company also runs marketing campaigns, service alerts, or other mass communications to the same contact base, those categories remain subject to the 600 or 809 scheme as applicable. Mixing types of communication without a clear internal classification is the gray area worth resolving before assuming the entire operation falls outside the scheme.
A point not to lose sight of: the exclusion from the Subtel regime does not modify the substantive rules governing extrajudicial debt collection. Law No. 19,496, and in particular its article 37 —which regulates the permitted and prohibited practices in extrajudicial collection management— remains in force unchanged. RE900 answers a question about telecommunications, not about the conditions of collection itself.
Are you clear about which communications in your operation qualify as extrajudicial debt collection and which remain subject to the 600/809 scheme? Schedule a session to define that perimeter before reconfiguring your campaigns.
What you can do
If you carry out or contract telephone extrajudicial debt collection, three concrete actions:
- Review your contracts with telecommunications operators. If you adjusted agreements to comply with Ordinance No. 11,269 —incorporating 600 or 809 prefixes into your collection operation— assess whether those contractual obligations remain relevant. The regulatory basis that justified them was annulled by the Supreme Court and its exclusion formalized by RE900.
- Update the compliance file of your operation. Document the change: keep RE900, the Supreme Court judgment (Case No. 41,033-2025, of March 5, 2026), and the previous operating protocol. The traceability of why you used the previous scheme and why you no longer do is part of orderly regulatory compliance management.
- Define precisely which communications qualify as extrajudicial debt collection. Not every contact with a debtor does. If your campaigns include mixed activities —payment reminder plus settlement offer plus product notification in a single flow— it is advisable to define internally how each type of contact is classified before assuming your entire operation falls outside the 600/809 scheme.
If any of these points raises questions —especially the classification of your mixed activities— a 30-minute diagnostic session is enough to size up your gaps. Schedule here.
If you need to review your telecommunications contracts or assess the impact of RE900 on your extrajudicial debt collection operation, schedule a meeting with our team
This content is informational and does not constitute legal advice.