AAIP launched a special investigation against debt collection firm 5 ON LINE S.R.L in April 2026. This case defines the compliance boundaries for debt-collection A2P SMS and voice services and serves as a strong warning for cross-border debt collection communications businesses.
The investigation stemmed from user complaints. While conducting debt recovery activities, the involved company contacted not only debtors but also harassed unrelated third parties including debtors’ relatives, colleagues and neighbours, suspected of violating Argentina’s Personal Data Protection Act (Ley 25.326). AAIP explicitly clarified that outsourcing debt collection activities to third parties does not exempt the principal from legal liabilities; the entrusting party and commissioned collection agency bear joint and several liability.
Regulators confirm that debt collection messages qualify as quasi-commercial communications. Even with valid debt agreements, unrestricted SMS and call harassment is prohibited, and an unsubscribe option must be offered to recipients. This rule directly applies to all A2P service providers undertaking debt collection SMS and voice traffic. Verified infringements may result in warnings, fines and service suspension. In severe cases, corporate operational databases can be sealed or deleted.
Guidance for overseas operators: When running debt-collection A2P services in Argentina, harassment of unrelated third parties is forbidden and unsubscribe mechanisms must be implemented. Even if local SVA licensed providers are engaged, the originating company retains joint liability and cannot rely solely on outsourcing to evade compliance risks.
