Understanding Regulatory Bundle Rejections – Twilio Support

After a Regulatory Bundle is reviewed a status update email will be sent. This notification is only sent to the email provided in the Notifications section of the bundle at the time the bundle was created. All other users will need to review the bundle status from within the Console.

If a bundle is rejected you will want to visit the Console to review the rejection reason. One or more of the supporting documents within the bundle may have been rejected. A supporting document may be rejected for more than one reason.

Table of Contents

Why Bundles Can Be Rejected
Best Practices for Document Submission
Bundle Rejection Reasons
- “The document you have uploaded does not match our Regulatory Requirements criteria”
Possible Bundle Rejections Reasons
Country Specific Rejection Reasons
Learn more here

Why Bundles Can Be Rejected

Bundles and the supporting documents that user’s associate with them can be rejected for a variety of reasons, but what’s important to consider when submitting documentation for a bundle is that the following conditions are met:

All documents within the bundle meet the requirements listed in our regulatory guideline pages.
Documents are legible, clearly readable, unredacted and valid (not expired).
Documents have to reflect the current/updated details of the business/individual.
Information required by the regulatory guideline pages is provided in the correct bundle fields.

Best Practices for Document Submission

Document Type	Best Practices
General	Document is valid (not expired) Document is readable (good quality without redactions) One document category should contain only one document, even if the document has multiple pages - all of them have to belong to the same document (we cannot accept multiple pieces of documentation merged together) We cannot approve a bundle unless all the documents within are approved. Therefore if the document was rejected because it cannot be accepted, it should be removed from the bundle before uploading alternative acceptable document (please do not remove rejected documents if rejection reason is not related to the document itself, but, e.g. with the way the address details were inputted into the bundle fields. That means that the document was acceptable, just data in that document bundle category has to be amended). All fields should be filled out with the same information as displayed on the provided supporting documents. Only information confirmed by a specific document should be inputted into that specific document’s bundle fields.
General Business	The document has to contain the most updated/current information about the business. If the document has been issued longer than 1 year ago, or if our Regulatory Compliance Team does further investigation, the team double checks the information in publicly available databases. If the current information in the database does not match information in the document provided, RC Team will reject it, requesting a newer issued document. Please always refer to regulatory pages as some countries have specific document date issue requirements (e.g. HK regulatory pages require documentation confirming the address to be issued in the last 3 months. Screenshots of business documentation, such as a screenshot from a governmental database can be accepted as long as the URL address is visible as well, so the team could be sure of the screenshot’s source. Always make sure that the information requested by the regulatory pages is provided in the bundle even if the bundle fields are named differently (e.g. Regulatory pages for AU Mobile number require to provide Business ID Number into the bundle, but there is no field named like this in the bundle. In the bundle you are asked to fill out a Document Number field but there is no requirement for document number in the regulatory pages. In that case it is safe to assume that the Business ID Number should be inserted into the Document Number bundle field.) Twilio cannot accept application forms as documentation. Please input the full business name as per documentation in the bundle fields, and not an abbreviation or a trading name. Business trading name can be inputted into the bundle fields if that trading name is also confirmed with the documents.
General Individual	The ID documentation for the individuals should meet the following requirements: If it is an ID card, both front and back sides should be merged into one document and uploaded into the same document category. Document must be in color. All edges/corners of the document should be visible. Contents on the document cannot be redacted. Document must be a scan of the ID and not a photo of the ID. Document has to be valid (not expired) if it has an expiration date Please always make sure to input all last names in the Last name bundle fields. Please input the full name as per documentation in the bundle fields, and not an abbreviation or a nickname (e.g. Nick in the bundle fields vs. Nicholas in the document will be rejected due to name discrepancy)
Proof of Address	Address documents for businesses should be issued within the last 1 year, and can be double checked in public databases/online research. Address documents for individuals should be issued in the last 3 months (unless the address is confirmed with ID, in which case there is no date requirement as long as the ID is valid). Ensure the document has your business/individual name that matches the business name on your business registration document or individual name on ID documentation. Ensure the address fields of a document aren’t left blank when the document is being used to verify address. The address documents should be issued by a third party source. The address documents should contain a full physical address (we cannot accept virtual offices/PO boxes). Address documentation has to fall into one of the address document categories listed in regulatory pages. E.g. if the document is uploaded as Utility bill, it should refer to actual utilities. If the document is uploaded as Tax Notice (not to be mixed up with Tax invoice), it should refer to the governmental communication regarding taxes. Twilio cannot accept application forms, nor lease agreements/rental contracts unless the signatures of all parties are visible. As alternative documentation for all bundle types, Twilio also accepts Bank Statements. Please make sure to select the correct address country in the bundle fields. If you accidentally saved a document with an incorrectly selected country, please note that it is tricky to amend. In those cases please remove the document from the bundle, and re-upload it back again; during this process you will be asked to input the address details anew and will be able to select the correct address country.

How to Identify Why Your Bundle Was Rejected

Navigate to the bundles page: Phone Numbers > Regulatory Compliance > Bundles (https://console.twilio.com/us1/develop/phone-numbers/regulatory-compliance/bundles?frameUrl=/console/phone-numbers/regulatory-compliance/bundles)
Click through to the rejected bundle (will say ‘Rejected’ under status column)
- After opening the bundle the top timeline will also display this rejection status.
Under Supporting Documents, find the rejected supporting document(s) and click to open the impacted support document.
Make note of the given bundle rejection reason
Make the necessary changes to the support document to align with regulatory requirements.
Repeat this process for each supporting document that was marked as rejected as each document may have a different rejection reason.
Double-check your email inbox in case our Regulatory Compliance Team has reached out with elaboration on your bundle rejection (if the system suggested rejection reason is not sufficient, a separate email is sent to the customer by the Regulatory Compliance Team to provide more details on why the Bundle has been rejected.)
- Please note that we contact the email address that the user designates for Notifications within the bundle, so please make sure that this address is relevant and monitored.
Always refer to the regulatory guidelines when checking your bundles to see if the document matches the acceptable documents listed, assuming all information required is provided in the bundle.
If you are still unsure about why your bundle was rejected, you may reply to the automatic email that containing information about your regulatory bundle status, and it will put you directly in contact with our Regulatory Compliance Team.

Bundle Rejection Reasons

“The document you have uploaded does not match our Regulatory Requirements criteria”

This rejection is given for any supporting documentation uploaded that doesn’t satisfy a country’s regulatory requirements - i.e. a screenshot of an email thread for costs incurred for utilities instead of an actual utility bill.

If you see this rejection, revisit the country’s regulatory guidelines for the specific needs of that country.

Possible Bundle Rejections Reasons

Below is a list of reasons that a document may be rejected for.

Many of the given rejection reasons are self-explanatory.

The Supporting Document is not legible. Please upload a readable Supporting Document.
The Supporting Document you uploaded has expired or it does not show an expiration date. Please provide a valid Supporting Document.
The Proof of Identity needs to show the front and back of the ID. Please upload a copy of the front and back of the ID.
The Authorized Representative is not shown on the Business Registration. Please upload a Supporting Document that shows the Authorized Representative of the business.
Please upload the Supporting Document without any redactions/information covered.
You’ve uploaded Business Registration as a Supporting Document. Please ensure the Business Registration shows the legal representative and upload an ID of the legal representative.
A Letter of Authorization (LOA) is required. The LOA needs to be signed and recently dated.
Business Registration is missing. Please upload Business Registrations as a Supporting Document.
Please provide a document issued in the last three months.
There is missing information. Please fill out the required form fields.
Please amend information provided in the Regulatory Bundle, the data does not match the Supporting Document provided.
The date of birth indicates an age under 18. Please ensure the birth date is at least 18 years old.
Required information is missing. The Birth Date, Birth Place, Tax Code, Document Type, Number, and Issue Date are required.
The name on the Supporting Document does not match the information entered on the Identity. Please ensure the names match exactly.
The nationality of the government office that issued the document does not match the information on the Proof of Identity. Please ensure the document and the information you provided match.
Please provide a Supporting Document that shows a local address.
Please amend the data entered in the Address fields to match exactly the address in the documents you have provided and ensure it is entered appropriately and in the correct sections.
A partial address is not accepted. Please provide a complete physical address.
The Proof of Identity does not show a visible address. Please upload a Supporting Document that shows an address.
A PO Box is not acceptable where a local address is required. Please provide a full physical address.
The End-User’s valid, government-issued photo identification with an address is missing. Please upload the End-User’s government-issued photo identification with an address.

Country Specific Rejection Reasons

Australia:

ABN/ACN number might be missing in Document number field

Italy:

Please amend the Tax Id Number and VAT fields in the Business & legal representative information section.
Please provide the Fiscal Code (Tax ID or equivalent) of the Authorized Representative in the Tax Id Number and company’s VAT number (or Business Registration ID, if VAT is unavailable) in the VAT field.

Germany:

Please note that Twilio doesn’t offer German Mobile numbers to individual end users (including Sole Traders, Freelancers and GbR). The information that neither German Mobile nor German Local numbers are available for individuals can be found on the German regulatory guidelines page. For Local numbers Twilio has however decided to make an exception and offer the local numbers to the Sole Traders, Freelancers and GbR.
Since Sole-Traders, Freelancers as well as civil law partnerships (Gesellschaft bürgerlichen Rechts - GbR) have no obligation to enter with the commercial register and do not systematically hold an excerpt from the commercial register (Handelsregisterauszug), please make sure to provide the following documentation instead:

Sole-Traders and civil law partnerships (GbR):

Gewerbeanmeldung, Gewerbeummeldung or Empfangsbescheinigung für Gewerbeanmeldung should be uploaded as Proof of Identity and Address under the Trade license document type.
Government-issued ID displaying a German Address for the business representative displayed on the Gewerbe or a Government-issued ID merged with 1 of the Registration Certificates (Anmeldebestätigung or Meldebescheinigung) should be uploaded under the Excerpt from the commercial register document type.

Freelancers:

Bestätigung Freier Beruf Finanzamt should be uploaded as Proof of Identity and Address under the Trade license document type.
Government-issued ID displaying a German Address for the business representative displayed on the “Bestätigung Freier Beruf Finanzamt” or a Government-issued ID merged with 1 of the Registration Certificates (Anmeldebestätigung or Meldebescheinigung) should be uploaded under the Excerpt from the commercial register document type.

Germany/Switzerland:

Business registration documents in these countries contain both outdated and current information. If the business name or address changed, the old name and address might be listed in the document - marked/underlined/crossed out in red or black color. Please make sure that you do not put outdated information into the bundle fields, and search the document for unmarked current information.

Hong Kong:

As per Hong Kong country's regulations we need to confirm Business Name, Business Address and Business Registration number.

Business address proof however has to be dated in the last 3 months. All three information could be confirmed with one document - the business registration certificate, that is currently attached to the bundle. However due to the 3 months rule, this certificate, while valid to confirm the Business Name and Business Registration number, cannot be used to confirm the address as well.

Therefore, we need to obtain an additional document issued within the last 3 months confirming the address, which can be one of the following:

Bank statement
Credit card account statement
Electricity bill
Water bill
Gas bill
Mobile telecommunications service bill
Fixed telephone service bill
Internet access service bill
Pay TV service bill

Learn more here