Due to local regulations, some phone numbers require a verified identity document associated with your Twilio project. Currently, German mobile and geographic and Italian mobile and geographic numbers require end-user identity information on file. If you are using the numbers directly, the identification should be yours or your company’s. If you are reselling the phone numbers, the identification should be that of your customer -- either an individual or a company identification.
If a phone number requires an identity document to be on file prior to purchasing, you will see a message in Console or an error message from the API (Error 21650) pointing you to the Console page where you can upload the required documentation. For help uploading and mapping identity documents, please see our article How do I upload and Map an Identity Document.
What type of identification is required for an individual? For a business?
Germany: If the end user is an individual, the end user must provide a valid, government-issued photo identification. If the phone number is being used by a business, either an individual employee must provide their photo identification (passport, national ID card, driver's license) or the business must provide a company identification document, i.e. excerpts from the trade register (in Germany: Handelsregister, Gewerbeanmeldung, or screenshots of the proof of registration from the German Commercial Register), excerpts from an association register (in Germany: Genossenschaftsregister, Partnerschaftsregister), a corporation’s founding documents, or other comparable documents.
Proof of Address: Regulations in Germany require that users of geographic numbers are located in the area of the phone number (i.e. a Munich prefix requires a Munich address). To ensure compliance with this rule, the Identity Document on file for geographic numbers must show the residence or business address matching the address on file in your Twilio account. You can add an address to your Twilio account here. Once you've added an address to your account, follow the instructions here for uploading and mapping an identity document with proof of address.
Italy: If the end user is an individual, the end user must provide a valid, government-issued photo identification from any country (passport, national ID card, driver’s license). If the phone number is being used by a business, a signatory for the business must provide their photo identification and details. In addition, the name and VAT code (see question below for details) of the business must also be provided.
What fields are mandatory for each country?
Identity records are not country-specific. If the required fields are populated, the same identity record can be used to buy numbers in multiple countries. For example, a validated individual identity record used to purchase Italian numbers, includes all the necessary fields to purchase German mobile numbers, and therefore can be used without modifications.
Germany: If the end user is an individual, the following fields are mandatory: Given Names, Surname, Document Nationality (any country is acceptable), Document Scan. If the user is a business: Business Name, Document Nationality, Document Scan.
Italy: If the end user is an individual, the following fields are mandatory: Title, Given Names, Surname, Birth Place, Birth Date, Nationality, Tax Code, Document Type, Document Nationality, Document Number, Document Issue Date, and Document Scan. If the user is a business, all the fields above plus Business Name and VAT are required.
What do 'Tax Code' and 'VAT' refer to?
These are unique identifier codes used to identify a person or business for tax purposes. For individuals, this is an identifier like Social Security Number in the U.S. or National Insurance number in the U.K, and should be entered in the ‘Tax Code’ field. For businesses, it refers to a unique identifier used by the entity when submitting tax forms, for example a Value Added Tax number in Europe or EIN in U.S., and should be entered in the ‘VAT’ field.
Can I have multiple identity documents on my project?
Yes, you can have multiple identity documents on your project or subaccount. Identity records are not shared between projects and sub-accounts, but you can create identical identities on multiple projects or sub-accounts.
Can I purchase numbers while my identity document is pending verification?
The regulations unfortunately do not allow us to allocate a number that requires identity verification until we have verified the user’s identity. However, the mapping of a phone number to identity record can be changed, from one valid identity to another valid identity.
How will I know when my identity documents have been verified?
Initially, you will receive an email to the email address specified by you at the time of document upload. We plan to release an update in the coming months that will support verification status callbacks to a URL specified by you at the time of document upload.
Do you store my uploaded identity document?
We store the uploaded document alongside the information related to your identity record. For some countries, we can delete the uploaded document after we have used it for verification. If you would like us to delete your uploaded document, while keeping the identity record on your project, please contact firstname.lastname@example.org for assistance. To delete an Identity Document record completely, release any numbers associated with it and select "delete this identity" in the details section.
What has prompted these new requirements?
An increasing number of countries have passed laws that require Twilio to collect and verify the identification of the end users of phone numbers we allocate. In Germany, this provision was enacted by the German government as an amendment to the Telekommunikationsgesetz (TKG). In Italy, the regulator has passed legislation that mandates end-user registration for all phone numbers. We expect other countries to align to these requirements in the future.