In case you missed it, the business texting compliance situation is a hot mess at the moment. Mobile carriers may have rolled out new 10DLC regulations gradually, but without clear and consistent information, this still left business texting providers (and their customers) ill-equipped to prepare for and navigate through the changes.
So now, even though the 10DLC deadline has passed, thousands of businesses are still not registered and thus their text campaigns are being blocked—in many cases without their knowing.
If you're having trouble with 10DLC registration rejections, let this complete TCPA/10DLC checklist be your guide.
Table of contents
For each section, we link to a resource that provides more details as well as examples and templates.
Terms to know
- SMS: Short message service. Aka business texting.
- MNO: Mobile network operators, like AT&T, Verizon, and T-Mobile.
- 10DLC: 10-digit long code. 10-digit number used for business texting
- TCR: The Campaign Registry. This is the third party chosen by MNOs to vet and validate 10DLC numbers. Texts from unregistered 10DLC numbers are now being blocked completely by mobile carriers.
- CSP: Campaign service provider. The software/platform a business uses to text customers.
- DCA: Direct connect aggregator/direct connectivity agent. The service your CSP uses to provide texting services. The DCA is the liaison between the MNO and CSP.
- TCPA: Telephone Consumer Protection Act (TCPA rules summary here). Federal law, in place to maintain a secure and pleasant texting experience for consumers.
- CTIA: Cellular Telephone Industries Association (CTIA homepage). Helps maintain best practices among all players in the business texting ecosystem.
10DLC/TCPA checklist for business texting
Here is what you need to have in place in order to be compliant with the TCPA and CTIA . These are necessary in order to get your 10DLC number registered with TCR and prevent your text messaging campaigns from being blocked by mobile carriers.
1. 10DLC registration checklist
Here is a list of the information your business text provider needs from you in order to submit your 10DLC registration application:
- Tax details
- DBA/brand name
- IRS-issued EIN or TID
- Organization details:
- Business type (LLC, sole proprietor, or corporation)
- Industry and business type (non-profit, public, private, government)
- Contact details
- Organization address
- Primary contact
- Campaign details (your CSP will likely provide this information on your behalf)
- Types of messages you'll be sending
- Sample messages
- Proof of how people give consent to receive messages from your business
Resource: 10DLC Explained: How to Get Registered
2. SMS terms and conditions checklist
Create an SMS terms and conditions page or add an SMS section to your current terms and conditions page. It must include
- Program name
- Program description (types of texts, frequency)
- How to opt out
- How to get support
- Carriers not liable statement
- Message/data rates apply.
- Link to privacy policy
(Note that this is a general minimum requirement list, and not legal advice. Your legal rep will need to provide the full requirements for your terms and conditions.)
Resource: Guide to Creating SMS Terms and Conditions (with Examples and Templates)
3. SMS privacy policy checklist
Create an SMS privacy policy page or add an SMS section to your current privacy policy page. It must include:
- Accurate description of the SMS service, including when and what type of messages users will receive.
- List the kind of personal information you're collecting (name, email address, phone numbers etc).
- List the methods you use to collect personal data (a form, cookies, etc).
- Explain how you're using the personal data you collect (sending emails or text messaging, etc).
- Explain how you store, maintain, and safeguard the personal information you're collecting.
- Explain if, how and why you share personal data with third parties.
- Provide a method for correcting, verifying, changing, or removing personal information.
(Note that this is a general minimum requirement list, and not legal advice. Your legal rep will need to provide the full requirements for your privacy policy.)
Resource: Guide to Creating an SMS Privacy Policy (with Template)
4. SMS written consent checklist (opt-in)
Anywhere that you collect a consumer’s phone number for the purpose of reaching out to them via text, you must include the following on that form:
- The telephone number of the person who is giving permission to receive texts or calls
- The purpose of your campaign
- Text message frequency
- The following disclosures:
- By submitting/signing the form, the user is opting in to receive text messages. (we’ll provide verbiage on this in a bit)
- How subscribers can opt-out
- “Message and data rates apply.”
Translation: customers may be charged by their cellular service provider for receiving or sending text messages from their devices
- “Consent is not a condition of purchase.”
Translation: giving consent to text does not mean the consumer then has to make a purchase
- Link to terms and conditions: Your terms and conditions outline the rules of engagement for your website, for both your business and your visitors. They primarily protect your business.Your SMS terms and conditions can be its own page or a section in your existing page.
- Link to privacy policy: Your privacy policy discloses how you collect, store, and distribute user data. It primarily protects user rights. Your SMS privacy policy can be its own page or a section in your existing page.
Resource: Opt-In Messaging FAQs, Examples, and Templates
5. SMS campaigns - first text requirements
The first text of every SMS campaign must:
Additional resources
From Hatch
From the FCC (Federal Communications Commission)
From the CTIA (Cellular Telecommunications and Internet Association)
From The Campaign Registry (the third party that registers 10DLC numbers)
