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. 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:

• Effective May 27, 2024, all new long code purchases require an approved Regulatory Compliance (RC) bundle before buying.
  
  
• Starting September 30, 2024, all UK long codes must have an approved RC bundle to be compliant with Ofcom's new regulatory guidelines. After this date you will see more notifications appear in console alerting you that you have non-compliant numbers and these numbers will be at risk of service disruption if enforcements by the regulator are applied.
  
• Starting in January 2025, non-compliant numbers may be expected to experience brownouts

This regulation is only applicable for the UK Long Codes which include local, national, mobile, and toll-free phone numbers.

What do impacted customers need to do?

Leverage this Help Center article to identify the KYC information needed based on our account type. Once identified and gathered, take the following steps based on which submission method you use to submit an RC Bundle for approval, and assign your long codes to it:

For API users:

• Submit the KYC information through the RC API.
  • Follow these instructions to get started with Regulatory Compliance Public Rest APIs
    
    
• Once you submit the RC bundles, Twilio will review the details and approve or reject the bundles.
  • If your bundle is rejected, Twilio will share the rejection reason. Review the reject reason and resubmit your bundle with the appropriate information for approval.
    
    
• Once approved, assign your UK long codes to your approved RC Bundle.

For Console users:

• Submit the KYC information through the Twilio Console.
  • To create a Regulatory Bundle (RC Bundle), navigate to the Phone Numbers > Regulatory Compliance section, then select Bundles to enter and submit the form. This will give Twilio the necessary regulatory compliance details for a phone number. This information ensures the phone number meets the legal requirements of the country or region where it's used.
    
    
• Once you submit the RC bundles, Twilio will review the details and approve or reject the bundles.
  • If your bundle is rejected, Twilio will share the rejection reason. Review the reject reason and resubmit your bundle with the appropriate information for approval.
    
    
• Once approved, assign your UK long codes to your approved RC Bundle.

If you have a high volume of non-compliant long codes (i.e., ISVs that do not subassign, Enterprise accounts), two new tools were introduced to further support:

• Bulk Upload Tool: The bulk process will provide ISVs more flexibility, including the ability to skip document requirements and even accommodate some missing fields (e.g., registration number). This process is only available for existing customer bundle creation. 
  
  
• Embeddable: The Compliance Embeddable can help streamline compliance processes via enabling self-service for the ISVs’ customers as well as result in overall faster vetting times due to its built-in validation capabilities.

Frequently Asked Questions:

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

What is an emergency address?
An emergency address is the Twilio user’s physical address that is associated with their Twilio phone number. This address is only used for voice calls for emergency services in the UK to send help if necessary.

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 phone numbers.

My business is not registered. What should I do?
You should use an individual bundle if your business is not registered. 

I am getting an error while submitting the KYC details via API or Console. How do I move forward?
Find the error code in Twilio’s Error Code list to resolve the error. If the error persists, 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. We have a helpful guide to walk you through common bundle rejection reasons and how to correct them.

I have multiple RC bundles and many phone numbers. How should I assign phone numbers to RC bundles?
Each phone number should be assigned to a RC Bundle that represents the owner of the phone number according to the business name. You can assign many phone numbers to a single RC bundle.

What happens to my messaging or voice solutions if I do not submit my KYC information?
Traffic sent on non-compliant UK long codes is at risk of being blocked in 2025.

Are the Ofcom regulatory guidelines open to the public?
Yes. Ofcom released the guidelines to the public on November 15, 2022.