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Know Your Customer (KYC) in the United Kingdom

 

What is Know Your Customer (KYC)?

If you have built an A2P communications solution, you will be familiar with Know Your Customer (KYC) data. Originating from the banking industry, KYC is essentially customer information that is required to identify and verify an individual or business is who they say they are and commonly consists of name, address, and date of birth for Individuals and company name, registered address, business verification documents, etc for businesses. Over the past decade, carriers and regulators around the world have been working hard to create a more trusted and verified messaging and voice ecosystem for businesses to engage with consumers to protect consumers from spam, fraud, and bad actors.

 

The first step the global communications industry is taking to protect consumers is requiring businesses and organizations to submit their KYC information and become verified by the local authorities before they can begin texting or calling their customers. Currently, not all countries require KYC information, but as the communications industry evolves it is becoming more common.



KYC Requirements in the United Kingdom

Given the rise in scam and fraud over the last few years, the UK regulator issued updated Know Your Customer (KYC) guidelines that Twilio is implementing in 2024.

These new requirements will be put in place to protect consumers from fraud, spam, and bad actors by requiring businesses to submit and verify their businesses with Twilio..

 

Here are the timelines to note:

         Submitting regulatory documents for UK KYC long codes is now live via API.

  • Starting March 4, 2024, customers will be able to share KYC information for them or their business via the Regulatory Bundles on Twilio console. These RC bundles will be vetted by Twilio after the submission.

  • Starting May 27, 2024 all new Long Codes purchases will require an approved Regulatory Compliance (RC) bundle before buying.

  •  Starting September 30, 2024 all new and existing UK long codes must be connected to an approved UK RC bundle to be able to send messages or make voice calls.

    This regulation is only applicable for the UK Long Codes which include local, national, mobile, and toll-free phone numbers. We expect similar regulatory requirement for alpha senderID for the UK later in 2024 and will send a further advisory on this.

What KYC information will be required for businesses in the UK?

Individual: Local or National

Information Required Documentation Required Acceptable Documentation
One of the following
Name Proof of Identity
  • Government-issued ID
  • Passport
UK Address

Must be a valid United Kingdom address.
Proof Of Address
  • Government-issued ID showing local address
  • Utility bill
  • Tax notice
  • Rent receipt
  • Title deed

UK Emergency Address
(if different from the address provided above) Must be a valid United Kingdom address.


 

No documentation required  
Date of Birth No documentation required  
Phone Number

This must be a valid mobile number only where the customer can be reached. This cannot be a number which you've acquired from a CPaaS provider such as Twilio.





No documentation required  
Email No documentation required  
Comments (optional) No documentation required  


Individual: Mobile or Toll Free

Information Required Documentation Required Acceptable Documentation
One of the following
Name Proof Of Identity
  • Government-issued ID
  • Passport

Address

Must be a valid address. May be anywhere in the world.


No documentation Required  

Emergency Address 
(If different from the address provided above)

Must be a valid address. May be anywhere in the world.


No documentation Required  

Date of Birth

No documentation required  

Phone Number

This must be a valid mobile number only where the customer can be reached. This cannot be a number which you've acquired from a CPaaS provider such as Twilio.



No documentation required  

Email

No documentation required  

Comments (optional)

No documentation required  

 

Business: Local or National

Information Required Required Documentation Acceptable Documentation
Business Name

Proof of Identity

(Documentation is required for businesses not using a UK Companies House Registration Number)

  • Excerpt from the commercial register

 

Registration Authority

 

 

 

Proof of Identity

(Documentation is required for businesses not using a UK Companies House Registration Number)

 

  • Excerpt from the commercial register
Business Registration Number

Proof of Identity(Documentation is required for businesses not using a UK Companies House Registration Number)

  • Excerpt from the commercial register
Website Address No documentation required  
UK Business Address

Must be a valid United Kingdom address
No documentation required  

UK Emergency Address (If different from UK Business address) 

Must be a valid United Kingdom address

No documentation required  
Authorized Representative's* Name

This must be a valid mobile number only where the customer can be reached. This cannot be a number which you've acquired from a CPaaS provider such as Twilio.

No documentation required  
Authorized Representative's Work Email No documentation required  

Business Classification

Direct Customer - My business uses Twilio to communicate internally or with our customers.

Independent Software Vendor (ISV) Reseller, or Partner - My business uses Twilio in a product that I sell to my customers.

No documentation required  
If you are an Independent Software Vendor (ISV), will you assign the Twilio phone number(s) to your end customers? (Yes/No) No documentation required  
Comments (optional) No documentation required  

*Authorized representative should be a senior person in the company who is responsible for Phone Numbers.

 

Business: Mobile or Toll Free

Information Required Required Documentation Acceptable Documentation
Business Name



Proof of Identity

(Documentation is required for businesses not using a UK Companies House Registration Number)

  • Excerpt from the commercial register

 

Registration Authority
(Name of entity where your business is registered if it is not UK Companies House)

Proof of Identity

(Documentation is required for businesses not using a UK Companies House Registration Number)

  • Excerpt from the commercial register
Business Registration Number Proof of Identity
(Documentation is required for businesses not using a UK Companies House Registration Number)

  • Excerpt from the commercial register
Website address No documentation required  
Business Address

Must be a valid address. May be anywhere in the world
No documentation required  
Emergency Address (if different from business address) May be a valid address. May be anywhere in the world No documentation required  
Authorized Representative's* Name No documentation required  
Authorized Representative Phone Number 

This must be a valid mobile number only where the customer can be reached. This cannot be a number which you've acquired from a CPaaS provider such as Twilio.
No documentation required  
Authorized Representative's Work Email No documentation required  

Business Classification:

Direct Customer - My business uses Twilio to communicate internally or with our customers.


Independent Software Vendor (ISV) Reseller, or Partner - My business uses Twilio in a product that I sell to my customers.

No documentation required  
If you are an Independent Software Vendor (ISV), will you assign the Twilio phone number(s) to your end customer(s)? (Yes/No) No documentation required  

Comments (optional)

   

*Authorized representative should be a senior manager in the company who is responsible for phone numbers.


What you need to do?

Follow these steps if you're an API user:

1. Prepare for the change in requirements and start collecting the required information and documentation on your end

2. Start submitting the KYC information through the RC API after January 29th, 2024 (please do not submit the KYC information before January 29th, 2024), otherwise it will be automatically rejected.

3. Once you submit the RC bundles, Twilio will review the details and approve or reject the bundles.

4. If your bundle is rejected, Twilio will share reject reason, please understand the reason and resubmit with the appropriate information and get your bundle approved.

5. Start connecting your approved bundles with your existing UK Long codes after May 27, 2024.

6. If you have any new UK long code purchases coming up after May 27, 2024, please get your RC bundle approved proactively to avoid disruption to your services.

7. After May 27, 2024, if you buy a new UK long code, you will need to connect an approved bundle before buying.

8. All UK long codes which were purchased before May 27, 2024 will need to be attached to an approved RC bundle by September 30, 2024 to avoid service interruptions, we would encourage you to proactively connect all your LCs to approved RC bundles after May 27, 2024.

 

Follow these steps if you're a console user:

1. Prepare for the change in requirements and start collecting the required information and document on your end.

2. Start submitting the KYC information through the Twilio console after March 4, 2024, you will not be able to submit the KYC information before March 4, 2024.

3. Once you submit the RC bundles, Twilio will review the details and approve or reject the bundles.

4. If your bundle is rejected, Twilio will share reject reason, please understand the reason and resubmit with the appropriate information and get your bundle approved.

5. Start connecting your approved bundles with your existing UK Long codes after May 27, 2024.

6. If you have any new UK long code purchases coming up after May 27, 2024, please get your RC bundle approved proactively to avoid disruption to your services.

7. After May 27, 2024, if you buy a new UK long code, you will be required to connect an approved bundle before buying.

8. All UK long codes which were purchased before May 27, 2024 will need to be attached to an approved RC bundle by September 30, 2024 to avoid service interruptions, we would encourage you to proactively connect all your long codes to approved RC bundles after May 27, 2024.


Detailed overview of the process of creating an RC bundle on the Twilio RC API:

Getting started - Regulatory Compliance Public Rest APIs
Create a new regulatory bundle

 

Process of creating an RC bundle on the Twilio Console:

Create a new RC bundle
Assign approved RC bundles to a UK Long Code


Frequently Asked Questions:

Will there be any fees for registering my UK long codes?
No, there is no fees to register UK long codes

I am an individual customer and I don’t have the required identity or address document, what do I do?
Unfortunately, you will not be able to use Twilio’s UK long codes without proper documentation

I am a business customer and I don’t have the company documents, what do I do?
If your business is registered in the UK house register, then you don’t need to upload your documentation, just provide the information which we will verify. If you are not registered in the UK then please reach out to us.

What do you mean by emergency address?
Physical address of the actual user of the Twilio Phone Number where emergency services can send help in case of an emergency

My business is not registered in the UK, which long codes am I eligible to use?
You should use UK Mobile or UK Toll Free numbers

My business is not registered, what do i do?
We encourage you to register your business.

I am getting an error while submitting the KYC details via APIs or console, how do I move forward?
Error will have an Error code, look up the Twilio’s error codes repository to understand the problem and try to resolve it, if it persists, please reach out to Twilio’s support team

My RC bundle is rejected, what do I do?
Your rejection email will contain the rejection reason, please review the rejection reason and resubmit the bundle with updated details

I have multiple RC bundles and many numbers, what logic should I use to assign phone numbers to RC bundles?
You should not have duplicate RC bundles, each RC bundle should have unique details. Assign the RC bundles to the Phone number that align with the bundle details. Ex: a phone number used from the London office, so the appropriate RC bundle should be assigned.

I have the KYC information and documents to submit, what I can’t submit before the set dates of Jan 29, 2024 for APIs and Mar 4, 2024 for Console?
You can’t submit anything before Jan 29, 2024. You can only submit the KYC details via API between Jan 29, 2024 and March 4, 2024. You can submit KYC details via API or Console after March 4, 2024.

What happens to my messaging or voice solutions if I do not submit my KYC information?

Unfortunately Twilio customers will not be able to buy new UK Longcodes without an approved UK RC bundle after May 27, 2024,. Existing numbers purchased before 27 May which do not have a KYC bundle by 30th September will have all traffic blocked.

Are the Ofcom regulatory guidelines open to the public?
Absolutely, Ofcom released the guidelines to the public on November 15, 2022.  You can access them by clicking on this link.




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