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Toll-Free Verification and Developers: Navigating the New Restrictions

As of January 31, 2024, messages sent from any unverified (Restricted or Pending) Toll-Free phone numbers (TFPN) are blocked in the US and Canada. Only fully verified Toll-Free phone numbers are eligible to send messages.

Blocked messages will return Error 30032 (any message sent from a Restricted or Pending TFPN) or Error 30007 (if spam/unwanted on a verified TFPN), and are subject to messaging fees.

“Restricted” means that the TF number has not yet been submitted for verification or that a verification submission was rejected. A TF number that has been submitted for verification but where that submission is still in process is in a “Pending” state.

These restrictions on unverified TF numbers do not apply to Voice or any other non-SMS use of that TF number or SMS messages sent to numbers outside the US. More about this here: Toll-Free Message Verification for US/Canada

The following topics are covered in this article:

What is Toll-Free Verification and why do we do it?

For the past several years Twilio has urged users to get their Toll-Free numbers verified, and at this time the vast majority of Twilio TF traffic is in a verified state. Verification is the telecom industry’s way of ensuring that messages sent from Toll-Free numbers:

  • come from a legitimate source,
  • have a legitimate purpose, and
  • that the recipients of these messages have agreed to receive them.  

Accordingly, the verification application process involves three key components:

  1. Establishing the identity of the business sending the messages: this includes providing a business name, address and website
  2. Clearly defining the business use case for which the messages are being sent, and providing several sample messages aligned with this use case
  3. Clearly describing and demonstrating the opt-in mechanism by which end users consent to receiving these messages

Beyond stating these three key pieces of information, to qualify for verification a number must also not be used for any of the forbidden categories of business messaging as outlined in this support article.

Twilio accounts can have unverified TF numbers for several reasons. US and Canadian Free Trial accounts are currently provisioned with a free TF number, and this practice will continue for the near future. This number is unverified to begin with and won’t be able to send messages, though the Free Trial console experience urges users to proceed with verification of that number as soon as they are ready to do so. On the other hand, users with paid accounts may have purchased a new Toll-Free number and not yet submitted that particular number for verification.

In either case, proceeding quickly with the verification process is our recommended practice, and after Nov 8th is the only way to avoid message blocking in the US, provided that users have the necessary information for a successful verification submission, as outlined above.

If you are a Sole Proprietor without a Business Tax ID and want to try sending SMS with Twilio, consider registering for an A2P 10DLC Sole Proprietor Campaign.

Impact on Trial Accounts

If you are signing up for a new Free Trial account, and are doing so in order to explore Twilio messaging technology on behalf of an established business, of whatever size, you should similarly be able to use that business’ identity information and it’s most likely use case for messaging, and at least concretely imagine a plausible opt-in mechanism appropriate for your business. In this case the only impact of the post-Nov 8 TF restrictions is that, upon signing up for Free Trial, you will need to at least submit your verification request first. After Jan 31, 2024, your number will need to be fully verified in order to send messages.

Twilio understands that not all users with Free Trial accounts have opened those accounts in the service of an established or prospective business. If you are a student, hobbyist developer, or anyone else trying out Twilio messaging with no immediate business motive, we encourage you to see if a Sole Prop registration makes sense for you. As we indicated in our recent blog post on the Toll-Free changes, “Toll-free numbers are designated for medium/large business messaging and are not meant to be used for hobbyist developers.”  

Register as an A2P 10DLC Sole Proprietor

If you are about to sign up for a Free Trial or have been using Twilio messaging from a Toll-Free number for some time in an unverified state but do not represent a business, one option worth considering is upgrading to a paid account, obtaining a local 10DLC number, and then registering it for an A2P 10DLC Sole Proprietor Brand.

The A2P 10DLC registration process is a means of gaining regulatory approval to send SMS messages in the US via 10DLC numbers (local 10-digit numbers, e.g., 415-123-4567) as opposed to Toll-Free numbers, and in general, this process relies on the same key pieces of information: establishing the identity of the sender; establishing that the messages are being sent for a clear and legitimate purpose (and, again, do not fall into any of the forbidden categories, which are identical for 10DLC and TF); and establishing that the sender has a clear opt-in mechanism for gaining the consent of receivers.

One significant difference from TF verification is that A2P 10DLC registration is NOT free: having purchased the 10DLC number, you must then pay a one-time registration fee and a monthly recurring fee. This is also why an A2P 10DLC registration can’t be pursued until you’ve upgraded to a paid account. But A2P registration also comes in different tiers, and the lowest tier, Sole Proprietor, is intended both for individuals running sole-proprietor businesses (where, for example, tax filing would be done with the individual’s social security number, not an EIN number) and can also work for “hobbyists” if they meet these registration requirements.

The good news is that A2P 10DLC supports Sole Proprietors without Business Tax IDs, including individuals with valid messaging use cases, among people eligible for 10DLC Sole Proprietor approval. In your campaign description, you can provide a short (2-3 sentence) description of the application you intend to build. For example:

“I send text messages to myself for {a description of your use case}. The messages will be related to {description of message content}.” 

Please note that our 10DLC review process will evaluate each campaign in collaboration with our vetting partner and make evaluations on a case-by-case basis. Before proceeding, we recommend familiarizing yourself with our forbidden messaging categories policy and our A2P 10DLC Sole Proprietor documentation.

We understand that paying for a 10DLC number, filling out, paying for, and waiting for an A2P Sole Proprietor registration is a significant commitment. However, if you are an established Twilio user who has been using an unverified Toll-Free number for non-business purposes and now find yourself blocked after Nov 8 and cannot qualify for Toll-Free verification, getting yourself a 10DLC number and going the Sole Proprietor route might make considerable sense.

If you are new to Twilio, have just signed up for Free Trial, and are not ready to make this commitment, we recommend trying the Twilio Virtual Phone.

Virtual Phone: The SMS Developer Sandbox

For users just beginning this journey, Twilio has created a Virtual Phone. The Virtual Phone can be thought of as a development sandbox environment for programmable SMS applications.

The Virtual Phone will first appear embedded in the Free Trial workflow and can subsequently be found in the Messaging area of the Console. As soon as you receive your free Toll-Free number (US only) as part of the Free Trial signup, you can use this number to message the virtual phone, making the same call to the same Twilio Messaging API you would use to send a message to your own mobile device. 

You can continue to use this Virtual Phone even after you’ve started exploring and building more elaborate messaging applications for which Twilio will make available the sample code. As long as you specify the Virtual Phone’s number as the To/recipient of your messages, any message that would otherwise show up in a physical mobile device will instead show up in the Virtual Phone. Because this number is not associated with a carrier, Messaging API calls to this number will not traverse the carrier network and, therefore, have no registration requirements. Messages sent to the virtual phone go directly to the virtual phone. 

The Virtual Phone will, therefore, be useful:

  • to immediately try out our Messaging API with your new Toll-Free number without first initiating verification on that number or
  • while you’re waiting for that Toll-Free verification application to be processed or
  • if you’re trying to get a feel for how Twilio’s messaging API works before deciding whether to proceed with Toll-Free verification or A2P 10DLC registration.
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