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Austria TKG 2021 + RTR/DSB Sender Rules

Austria (AT) is the high-volume DACH market whose rules split across two regulators instead of one. The telecom side sits with the RTR (Rundfunk und Telekom Regulierungs-GmbH), the office that serves the Telekom-Control-Kommission (TKK), which applies the Telekommunikationsgesetz 2021 (TKG 2021) — including the §107 opt-in regime for electronic marketing communications. The data-protection side sits with the Datenschutzbehörde (DSB), which enforces the Datenschutzgesetz (DSG 2018) alongside the GDPR. Over both, the E-Commerce-Gesetz (ECG) sets the commercial-communications baseline that makes a working suppression practice part of the posture. This page expands the AT row of the country-requirements matrix so you can close the Austrian items deliberately instead of re-reading one JSON blob per launch. Austria is a tenant-owned burden. Orbit never mandates your posture — it keeps the country-rules reference that feeds the send-time gates, and it gives you the consent ledger, sender-registration, quiet-hours, and opt-out surfaces below. The legal posture is yours.
This page is documentation, not legal advice. The DSB enforces the DSG 2018 and the GDPR against the sender, with administrative fines up to the GDPR ceilings, and the RTR’s sender convention is policed at the carrier edge. Have counsel review your consent capture and sender paperwork; Orbit supplies the surfaces.

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The Austria-specific rules

Read the AT row of GET /api/v1/compliance/country-rules?channel=sms (see Country Compliance Requirements). The live row is the send-time truth; this page documents the posture behind it.
Read sender_types, registration, content_restrictions, and stop_requirement from the AT row before every launch. A registry refresh can raise a row’s registration level (never lower it), so the row you read today is the one the gate enforces tomorrow. Consolidated:

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The two regulators — RTR for telecom, DSB for data protection

RTR / TKK (telecom). The RTR is the regulatory office; the TKK is the commission that decides telecom matters on top of it, and the TKG 2021 is the statute both apply. For A2P SMS the provisions that touch you are the §107 opt-in regime for electronic marketing communications and the sender identification convention the RTR maintains for traffic into Austrian networks. When a sender dispute or a registration question has a telecom flavour, it lands here. DSB (data protection). The DSB is Austria’s data-protection authority, and the DSG 2018 is the national statute it enforces alongside the GDPR. The consent record behind every AT marketing send has to survive DSB examination: a lawful basis, a timestamp, and a source the recipient would recognise. When a complaint arrives, it is the DSB that reads your ledger. The split is why Austria needs two ledgers kept straight: the sender paperwork answers to the RTR side, the consent and suppression evidence answers to the DSB side.

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The RTR alphanumeric sender-ID convention

Austrian carriers expect an alphanumeric sender ID into +43 to resolve to an originator the RTR-side paperwork can identify. There is no statutory register that holds your traffic at the gate; the convention works the way other European markets’ conventions work — a registered, authorised sender delivers, an unvetted one is the class carriers relabel or drop. The filtering you hit without the paperwork is deliverability, not an Orbit gate. The paperwork that carries the convention is the letter of authority: the brand named on the sender ID authorises the entity that originates the traffic, and the filing names both. The tenant-owned control that carries it in Orbit is the Sender-ID Registration submit-and-track flow — file the AT sender there with the letter of authority attached, and treat the approval state as a launch blocker for AT marketing traffic even while the live row’s registration level stays open. Orbit records the filing and the approval; the authority itself sits with you and your provider.
TKG 2021 §107 is Austria’s opt-in regime for electronic marketing communications: consent before the send, never after. The DSB reads silence, bundled consent, and pre-ticked boxes the same way German courts read them under UWG — they do not establish consent. For AT-bound marketing SMS the statute stack runs:
  • GDPR + DSG 2018 — lawful basis and provable consent for the processing behind the send. Record it the way the GDPR Posture Guide describes.
  • TKG 2021 §107 — Austria’s own telecom-layer addition: marketing by electronic communications is lawful only with the recipient’s prior consent.
  • Withdrawal symmetry — an opt-out must be as easy as the opt-in and must stop the traffic. A German opt-out reply fires the alias rule and writes a suppression entry scoped to all, so STOPP knocks the recipient off SMS, WhatsApp, and RCS in one event.
The consent record has to exist before the first marketing send and be provable on complaint. Give every record the fields the DSB will ask for:
  • the timestamp the recipient opted in (the consent-granted-at value),
  • the channel scope (sms for AT marketing SMS),
  • the source text the recipient saw at capture,
  • the proof pointer you export when counsel asks.
Record it in Consent Management before the first dispatch, and export it with timestamps from Archival Export when the DSB or counsel asks.

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The German-language STOP family

Austria shares its opt-out vocabulary with Germany. The seeded alias table already maps the DE family — STOPP, ABBESTELLEN, ABMELDEN, ENDE, plus case- and Unicode-normalised variants — to the suppression ledger, and the same aliases cover AT traffic; no separate Austrian seeding is needed. Confirm the aliases are live on your tenant and that each match writes the suppression entry scoped to all, exactly like the English STOP family. See Opt-Out Keyword Alias Table for the seeded set and the scope each alias writes, and the Germany page for the DE posture the aliases come from.

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The E-Commerce-Gesetz suppression ledger

The ECG’s commercial-communications regime expects that once a recipient objects, no further commercial message reaches them — on any channel the objection covers. The tenant-owned surface that carries this in Orbit is the suppression ledger described in Opt-Out Suppression: one tenant-owned ledger, entries scoped per channel or to all, written by the alias rule on a German STOP reply and by your imports for opt-outs captured off-platform (a support email, a paper form, an unsubscribe click). Scrub every AT audience against the ledger before each launch, and keep the entries exportable — when the DSB asks how an objecting recipient still received traffic, the ledger is the answer.

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RTR time-window guidance

Austria has no statutory no-send window like France’s 20:00–08:00 convention. What Austria has is the RTR guidance and a DACH complaint pattern that mirror the German 21:00–09:00 convention: marketing traffic that lands in the evening or the early morning produces the complaints the DSB prices. The tenant-owned control is the same deliberate opt-in as every other strict market: Where AT differs from FR: France’s window is a market convention surfaced in the country-rules content_restrictions; Austria’s is guidance plus a complaint pattern. Both end at the same configuration — you set tenant quiet hours deliberately — but nothing AT-specific appears in the rules row to remind you, so this page does.

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Where each AT obligation maps in Orbit

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AT launch checklist

Narrowed from the generic launch checklist in Country Compliance Requirements to the AT row:
1

Look up the AT row

Call GET /api/v1/compliance/country-rules?channel=sms&region=EU and read the AT row’s sender_types, registration, content_restrictions, and stop_requirement.
2

File the alphanumeric sender

Submit the AT sender ID with the letter of authority through Sender-ID Registration; under the RTR convention carriers filter unvetted alphanumeric traffic.
3

Capture marketing opt-in first

Record a consent entry with sms scope — timestamp, source text, proof pointer — before any AT marketing send; TKG 2021 §107 is opt-in, not opt-out. See Consent Management and the GDPR Posture Guide.
4

Wire the German STOP family

Confirm STOPP, ABBESTELLEN, ABMELDEN, ENDE are mapped in the alias table and write the suppression entry scoped to all. See Opt-Out Keyword Alias Table.
5

Scrub the suppression ledger

Scrub the AT audience against the suppression ledger before each launch; import off-platform objections as you collect them.
6

Set tenant quiet hours deliberately

If you run AT marketing traffic, turn on tenant quiet hours over Europe/Vienna recipient time, mirroring the German 21:00–09:00 convention — Orbit defaults this off. See Quiet-Hours Configuration.
7

Launch

With AT enabled on the tenant, the sender filed, consent captured, keywords wired, the ledger scrubbed, and quiet hours set, start sending.