U.S. carriers have created A2P messaging channels, such as short codes, Toll-Free numbers, and 10-digit long codes (A2P 10DLC) in order to give senders a sanctioned channel for messaging that will ensure consumers reliably receive wanted messages. Messaging campaigns that are non-compliant with carrier requirements may be subject to carrier penalties for the offending traffic.
Carrier policies are included in Twilio's policies. Any failure by Twilio's to stop non-compliant traffic is not a basis to contest. If these penalties are assessed, they will be passed through by Twilio to the customer. Below you can find a breakdown of the existing non-compliance fees, best practices for maintaining compliance, and our FAQ regarding these fees.
- T-Mobile Penalties for Non-Compliant Messaging
- How to Avoid Carrier Penalties for Non-Compliance
- Non-Compliant Messaging Penalties FAQ
T-Mobile Penalties for Non-Compliant Messaging
The current fines outlined below are specific to T-Mobile. These fees, if assessed by T-Mobile (or potentially other U.S. carriers) will be passed through to customers by Twilio.
Content violating carrier policies – as also reflected in Twilio's Acceptable Use Policy and/or Messaging Policy – including spam, phishing, and SHAFT violations (Sex, Hate, Alcohol, Firearms, Tobacco).
Fee: $10,000 per violation
Enforcement: T-Mobile will issue a warning prior to enforcing this fee. Twilio will relay this warning to you via an email to the users on your Twilio account who are opted-in to Compliance and Regulatory related alerts. This initial warning will give you an opportunity to come into compliance, without getting a fee.
If another violation occurs after the warning, Twilio will report the violation to you and pass this fee through directly on behalf of T-Mobile.
Messaging Program Evasion
Using filtering evasion techniques, such as snowshoeing and recycling numbers (releasing/purchasing new numbers), to dilute number reputation. (See our Messaging Policy for more context.)
Fee: $1,000 Fine
Enforcement: Twilio will report these violations to customers and pass these fees through directly on behalf of the carriers.
Grey Route Fees (not currently active):
Failure to migrate A2P traffic from a P2P connection to an A2P route.
Fee: $10 for each message sent on a P2P route (unregistered messages)
Enforcement: We anticipate that a date for Grey Route fees will be announced in 2022. Twilio will provide a 30 day advance notice before this fee comes into effect with more details on how customers will be notified.
How to Avoid Carrier Fees for Non-Compliant Messaging
Ensure Compliance with Twilio’s Policies
The best way to avoid fees for non-compliance is to make sure your traffic aligns with Twilio’s Messaging Policy and T-Mobile’s Code of Conduct. You can also refer to CTIA’s Best Practices documentation and adopt industry standards into your operations and/or services.
Register your traffic for A2P 10DLC
To avoid any future fees regarding Grey Route messaging, please ensure that you have registered your US traffic for A2P 10DLC as described in How Do I Register My Traffic for A2P 10DLC.
Non-Compliant Messaging Fees FAQ
How will penalties be issued to customers?
Fees issued through Twilio will be passed through directly to customers. At this time, Twilio is still working with T-Mobile to determine further details on how these fees will be issued to customers.
When will the grey route fee go into effect?
T-Mobile has not yet announced when the grey route fee will go into effect. We anticipate it will be implemented in early 2022. We will provide our customers at least 30-days notice before the grey route fee is live.
Will Twilio allow our customers to send grey route messages once the fees go into effect?
Twilio’s future intention is to block grey route traffic before it leaves Twilio’s platform to prevent customers from being charged the $10 grey route fee. However, we are still working with carriers to fully understand how the fees will be implemented and cannot provide a workflow experience or timeline at this point.
What does “snowshoeing” mean in the context of messaging?
Snowshoeing is defined as spreading similar or identical messages across many phone numbers with the intent or effect of evading unwanted messaging detection and prevention mechanisms.
I use multiple numbers in my Messaging Service for my use case. Would that be considered snowshoeing?
It is not considered snowshoeing unless you are intentionally spreading the same or similar message across more numbers than you need to evade detection/filtering, or to dilute a numbers reputation, ie. to keep it from being marked a ‘spam’ by the carriers.
An example of not snowshoeing: You could use Area Code Geomatch with multiple numbers to create localized experiences.
Will the Content Violation notification come from Twilio specifically?
Customers will receive notifications and passthrough fees for non-compliance directly from Twilio.
In the case of Content Violation, will Twilio suspend my traffic and help with remediation BEFORE the $10,000 fee?
T-Mobile will issue a warning prior to levying this fee. Twilio will relay this warning to you via an email to the users on your Twilio account who are opted-in to Compliance and Regulatory related alerts. This initial warning will give you an opportunity to come into compliance.
Please note that Twilio will also enforce its own policies independently from carriers through outreaches and other remediation efforts, including account restrictions or suspension. However, Twilio makes no guarantee that it will intervene in your non-compliant traffic before carriers levy the fees.
Are ISVs responsible for non-compliance fees on-behalf of their End Users?
The ISV is responsible for its End Users and would be considered the “content provider”. If an End User's act(s) results in a fine or fee imposed on Twilio, then Twilio will hold the ISV responsible for the same. Twilio imposes no restriction on the ISV from independently passing through the fine or fee to its customers.
Is there an appeals process if I believe I have been incorrectly fined for a compliance violation?
Yes. Twilio is still awaiting additional details from T-Mobile on how the appeals process will work for T-Mobile compliance fees. However, Twilio will conduct independent investigation into any reported compliance violations raised by carriers, and will work with you to appeal if the penalty appears to have been applied in error.