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What should I expect if my US or Canada short code is audited?

Your short code may be audited for compliance with carrier guidelines by the CTIA, CWTA or by individual carriers. Furthermore, Twilio proactively audits US and Canada short codes to help you ensure that your campaign is compliant and up to date with industry standards.

If your short code is audited and the campaign is found to be non-compliant, Twilio’s A2P Compliance team will contact you with a list of the identified issues and will let you know how to resolve them. You will typically be given a deadline of one week to resolve any issues, after which point your short code will be at risk of suspension if the issues have not been resolved.

If your short code is suspended by a particular carrier, it will take at least 30 days (and possibly longer) to restore service. Every time a short code is suspended by a carrier, it must go through that carrier’s provisioning process again to be re-approved.

Below is additional information related to common audit violations as well as the expected cure dates for resolution. 

US and CA*
Violation  Severity  Description of Violation Remediation Timeline  Penalty
Prohibited Content and/or SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco) Violation High

Content that is either explicitly prohibited or promotes unlawful, unapproved or illicit content. 

For more information please visit our Forbidden Message Categories for SMS and MMS in US and CA

Immediate  Immediate traffic suspension
Messaging sent without a valid or unapproved opt-in High

Message senders must have a compliant opt-in methodology in place at all times. If more than one program is running on a short code, end users must be allowed to select their preferred contact method by program type. Enrolling an end user in multiple programs is prohibited, regardless if it is the same brand and/or same short code. 

For more information please visit our Industry Standards for opt-ins for US Short Codes or Industry Standards for opt-ins for CA Short Codes

Immediate  Immediate traffic suspension
Unapproved Program High

All campaigns must be submitted to carriers for review and approval before traffic goes live. Prematurely sending traffic or deviating from the original use case prior to receiving the necessary approvals could result in an immediate suspension. 

The cure date provided for this violation is intended to allow time to revert back to the original use to avoid a traffic impacting event. 

For more information, please visit our Twilio Messaging Policy 

Immediate Immediate traffic suspension
Failure to comply with Opt-Out keywords  High

Opt-out keywords are considered mandatory in both US and CA. Not providing a compliant response when an  Opt-Out is triggered is prohibited. 

 

Carrier Opt-out requirements for the US can be found on page 8 of the CTIA Handbook; CA requirements can be found on page 21-22 of the CWTA Handbook 

2 Business Days Immediate traffic suspension
Failure to comply with HELP keywords   Med

Short Code programs should always respond to customer care requests, regardless of whether the end user is subscribed to the program. Customer care information can be a Toll-Free number or customer support email.   


Carrier Keyword requirements for the US can be found on page 11-12 of the CTIA Handbook; CA requirements can be found on page 21-22 of the CWTA Handbook 

5 Business Days Failure to comply during remediation may result in traffic suspension *
Failure to send opt-in confirmation Med 

Short Code programs should send an initial opt-in confirmation message verifying the end users enrollment in the program. Opt-in messages must contain the program (brand) name or product description, customer care contact information, message frequency disclosure, and the message rate disclosure (e.g message and data rates may apply”.


Carrier Opt-in requirements for the US can be found on page 7, 11 and 12 of the CTIA Handbook; CA requirements can be found on page 21-25 of the CWTA Handbook 

5 Business Days Failure to comply during remediation may result in traffic suspension *
Missing pricing disclosures (e.g. Message and Data rates may apply) Low

Short code programs should always have a pricing disclosure, unless it is a Free-to-End-User program. 

 

Carrier pricing disclosure requirements for the US can be found on page 7, 11 and 12 of the CTIA Handbook; CA requirements can be found on page 18 and 25 of the CWTA Handbook 

5 Business Days Failure to comply during remediation may result in traffic suspension *
Missing message frequency disclaimer  (e.g. 2msg/week) Low

Recurring message programs are required to have the message frequency displayed on the Call to Action (where end users opt-in) and also on their SMS terms. Opt-in confirmation messages and keyword responses should also have message frequency disclosed. 


US carrier requirements related to when a message frequency disclosure should be present can be found on page 12, 13 and 18 of the CTIA Handbook; CA requirements can be found on page 18 and 21 of the CWTA Handbook 

5 Business Days Failure to comply during remediation may result in traffic suspension *
Missing Program Name Low

All Short Code programs are required to disclose program names, product description, or both in service messages, on the call-to-action, and in the terms and conditions. 


Carrier requirements related to when a Program Name should be present can be found on page 10-12 of the CTIA Handbook; CA requirements related to content providers can be found on page 18, 21-22 of the CWTA Handbook 

5 Business Days Failure to comply during remediation may result in traffic suspension *
No link to SMS terms & conditions  Low

All programs are required to maintain up-to-date Terms and Conditions specific to their SMS program. SMS Terms and Conditions are required to be present in the initial call-to-action. 


Carrier requirements related to SMS Terms and Conditions can be found on page 10-12 of the CTIA Handbook; CA requirements can be found on page 18-19 and 25 of the CWTA Handbook 

15 Business Days*  Failure to comply during remediation may result in traffic suspension *
* The audit penalties listed above are determined by industry standards and intended to provide more clarity around penalties that could impact short code traffic. If you are unable to make the change within the given cure date, we cannot guarantee further enforcement will not occur at a carrier level.  Carriers operate on private networks and have the right to suspend a short code at any time if messaging policies are violated. US and CA may have different program requirements. For more information, you can refer to the CTIA Handbook for US best practices or the CWTA Handbook for CA Best Practices.

 

 

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