German Local Number Audit Results Explanation

General Instructions

Germany imposes strict requirements on local phone numbers. These instructions show you how to come into compliance.

You must prove that you reside in the same location as your numbers for each prefix-locality. So you will need documents proving that, and you need to submit them to Twilio.

In the Twilio interface you’ll create the addresses you need, and then upload your documents to prove each one. Then, you’ll (1) map each number, or group of numbers, to the appropriate document AND (2) map each number to the appropriate address.

Yes, you have to map each to each number (or group of numbers) to both the document AND the proven address.

Step 1: Gather proof of identity and proof of address document(s). The location of your phone numbers prefixes must match the city on your submitted document(s).  If you have numbers in more than one prefix location, you’ll need to upload more than one proof of address.

You can read more about required documentation on this FAQ.

Four forms of identification are acceptable (you need one to prove each address):

  1. Handelregisterauszug with an address on it
  2. Gewerbeanmeldung that doesn’t include an expiry date
  3. A valid German government-issued identification document that shows a German address (usually on the back of the card)
  4. A passport that lists the location of residence in Germany

    Due to changes in German regulatory policy, you must scan and upload the actual documents.  Screenshots of online sites, articles of incorporation, and the like are no longer permissible.

Step 2: Upload your documents in Console and map them to your numbers:

This step must be completed in full, or mapping your numbers is not done. Unmapped numbers are out of compliance and could be revoked.

  1. Fill in a valid German address in Twilio Console. This address must be in the same location as the prefix of the phone number you’ll be mapping it to. (e.g., a Berlin phone number must have Berlin address). You can use one address for multiple phone numbers so long as this address matches the numbers’ prefix.
  2. Upload a scanned copy of a valid identification document as described above in your Twilio Console. These are the only acceptable forms of documentation to remain in compliance.
    A quick note on addresses and documentation before we get to the next step: your valid identification document must serve also as a “proof of address”. Any address that you upload for your numbers must also match the address in the identification document that you’re uploading.
  3. Map both the address and the identity document to the relevant phone numbers. For how to do this, please see these instructions.

You may map multiple phone numbers to a single address and identification document combination so long as every phone number matches the location of the address and the identification document serves as a proof of address for that address.

If you completed the above, you are done and your numbers should be in compliance. Twilio runs automated processes to verify daily, and we will notify you as immediately as possible.

We urge you to take this process seriously, if we discover errors, there may not be time for you to correct them before your numbers are in jeopardy.

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Specific Instructions for your Audit Results

We’ve gone through and performed an audit on all of our existing inventory. We’ve identified which numbers are out of compliance and have designated the reason why.  Below, we’ve outlined each possible non-compliant reason, provided an explanation, and outlined steps that you’ll need to take to resolve the issue.

Reason 1: Mapped address is compliant; mapped identity document is noncompliant

Issue: You’ve given us a compliant address (thanks!) but there is an issue with your identity document that’s mapped to your phone number. This is due to 1 of 2 reasons:

  1. The identity document is not one of the four approved documents listed above
  2. The identity document does not serve as a “proof of address”. In other words, the address in the identification document does not correspond to the address that you provided for the phone number.

How to Fix: There are two possible ways to fix this issue:

First Option: Upload a new, valid Identity document with an address that matches the existing address

  1. Be sure that (1) the address in the identity document matches the address mapped to the phone number and (2) the identity document is one of the four accepted types of identity documents (see above).
  2. Map this identity document to the phone number.

Second Option: Reuse an existing Identity document. If you’re using an existing document, please do the following:

  1. Confirm the identity document is one of the four accepted types of identity documents
  2. Confirm the address in the identity document matches the current address mapped to the phone number. Please note, if your existing Identity Document is not one of the 4 types listed above, you cannot reuse it. Note that the identity documents in your account will not indicate whether the document is compliant or not.
  3. Map this identity document to the phone number.

After completing one of the two alternatives above, we will email you once we have verified the address information with a manual review. See details below in “How do I know if my number is in full compliance?”.

Reason 2: Mapped address is compliant; no compliant identity document is mapped

Issue: The address mapped you’ve to the phone number is compliant but you haven’t yet mapped a compliant identity document to the phone number.

How to Fix: There are two possible ways to fix this issue, depending on whether you already have a valid identity document uploaded to your account:

First Option: Upload a new valid identity document to Console.

  1. Be sure that (1) the address in the identity document matches the address mapped to the phone number and (2) the identity document is one of the four accepted types of identity documents (see above).
  2. Map the identity document to the noncompliant phone number.

Second Option: Use an existing identity document that you have already uploaded into Console. If you’re using an existing document, please do the following:

  1. Confirm the identity document is one of the four accepted types of identity documents
  2. Confirm the address in the identity document matches the current address mapped to the phone number. Please note, if your existing identity document is not one of the 4 types listed above, you cannot reuse it. Note that the identity documents in your account will not indicate whether the document is compliant or not.
  3. Map this identity document to the phone number.

After completing one of the two alternatives above, we will email you  once we have verified the address information with a manual review. See details below in “How do I know if my number is in full compliance?”.

Reason 3: No compliant address is mapped; no compliant identity document is mapped

Issue: Your number is missing both a compliant address and compliant identity document. You’ll need to add a compliant address, a compliant identity document to console and map both to your phone number(s) to become compliant.

How to Fix: There are two steps to fix this problem and there are two alternative for each step. The first step is to fix the address, and the second step is to fix the identity document:

Step 1: Fix your address:

    • Upload a new valid address to Console.
    • Be sure that the address matches the prefix of the phone number.
    • Map this address to the phone number.

OR

    • Use an existing compliant address you’ve already uploaded where the address matches the number’s prefix.
    • Map that address to the phone number.

Step 2: Fix your Identity document:

  • First option: Upload a new valid identity document to Console.
    • Be sure that (1) the address in the identity document matches the address mapped to the phone number and (2) the identity document is one of the four accepted types of identity documents (see above).
    • Map this identity document to the phone number.
  • Second option: Use an existing identity document that you have already uploaded to Console that matches your address. If you’re using an existing document, please do the following:
    • Confirm the identity document is one of the four accepted types of identity documents
    • Confirm the address in the identity document matches the current address mapped to the phone number. Please note, if your existing Identity Document is not one of the 4 types listed above, you cannot reuse it. Note that the identity documents in your account will not indicate whether the document is compliant or not.
    • Map this identity document to the phone number.

After completing the steps above, we will email you please check back  once we have verified the address information with a manual review. See details below in “How do I know if my number is in full compliance?”.

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How do I know if my number is in full compliance?

There are 2 parts:

  1. Once your number is mapped to a compliant address, you'll see a "compliant" notice next to the "Address" dropdown under the "Regulatory Information" section for your phone number.
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  2. If your identity document is not compliant or is not a valid proof of address, we’ll make sure to email you with audit results to help you solve the issue. Unfortunately, there is no indicator in Console that will tell you whether your identity document is compliant. We have to review those on our end and then email you.

German local numbers are in compliance with regulations when:

  • Each German Local number you own is mapped to both a validated address in the locality of the prefix and an approved identity document showing the same address or locality.
  • The approved document is one of four accepted types:
    • Handelregisterauszug with an address on it
    • Gewerbeanmeldung that doesn’t include an expiry date
    • A valid German government-issued identification document that shows a German address (usually on the back of the card)
    • A passport that lists the location of residence in Germany.

 

 

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