U.S. A2P 10DLC Registration Guide for Political ISVs

The purpose of this guide is to help Twilio customers who are Independent Software Vendor (ISVs) who have political end-customers, register for A2P 10DLC in the U.S..

In the U.S., Political Messaging is defined as part of an organized effort to influence decision making of a specific group. SMS from U.S. political campaigns, parties, and PACs is considered political messaging, as is issue-based advocacy messaging from 501(c) nonprofit organizations.

All organizations sending political messages over 10-digit long code phone numbers in the U.S. must register for A2P 10DLC (including ISVs that operate platforms used by other organizations to send SMS messages). Political ISVs must register for A2P 10DLC on behalf of their customers. Non-ISVs (Direct Political Customers) or ISVs not using the API, please see Nonprofit and Government Guide to A2P 10DLC Text Messaging to register via the Twilio Console.

By registering your customers and use cases, you can access improved delivery using the same phone numbers you have always used. For a full description of benefits that will be afforded to your political customers, based on 501(c) or 527 status, see Special Use Cases for A2P 10DLC.

Political messages sent from 10-digit long code phone numbers that are not sent via registered A2P routes are subject to filtering, fines, or suspension.

Types of Political Messaging Senders

Political messages may be sent by: 

  • Political campaigns, candidates, parties, PACs, or other committees: 527 political organizations using the Political Use Case. 
  • Advocacy organizations: IRS 501(c)(4), 501(c)(5), 501(c)(6) organizations using the Political Use Case. 
  • Civic participation organizations: (501(c)(3) organizations using the Charity Use Case for civic engagement campaigns. 

Campaign Verify

All IRS 527 Political Organizations including political action committees (PACs) sending political communications on behalf of a Federal, State, or Local political campaign must be verified by Campaign Verify in order to onboard successfully onto 10DLC and unlock the "Political" Special Campaign Use Case with increased messaging limits. Campaign Verify is a secure, non-partisan verification solution for U.S. Political organizations who wish to engage with voters via text messaging. Registration with Campaign Verify is a prerequisite to completing A2P 10DLC registration for IRS 527 Political Organizations. Successful registration will result in receiving a Campaign Verify token for the organization. This token must be provided during A2P 10DLC registration for all IRS 527 organizations

 As a Political ISV, you should instruct all IRS 527 customers to register with Campaign Verify here. Then, you will need to securely collect the tokens from your clients to provide during A2P 10DLC registration, and ensure a valid Campaign Verify token is on-file for their A2P Brand on an ongoing basis.

 Listed below are some important pieces of information about Campaign Verify registration:

  • There is a one-time $95 fee from Campaign Verify per entity verification per two-year election cycle.
  • If a Committee EIN is set during Campaign Verify verification (for state, local, or tribal verification only), this EIN will be cross referenced with the EIN used to register your A2P brand and must match.
  • A Campaign Verify token can only be imported once. If an IRS 527 organization is using multiple messaging providers, they should generate multiple Campaign Verify tokens — one per A2P Brand that is created on their behalf. 
  • 501(c) advocacy organizations (e.g. 501(c)(4) social welfare groups) do not register with Campaign Verify. They will unlock the “Political” special use case based on an automatic verification of their 501(c) status during A2P Brand registration and do not provide a token 
  • If you have additional questions about Campaign Verify registration, please refer to their FAQ or email support@campaignverify.org

Note: A 527 organization that does not register with Campaign Verify and provide a token during 10DLC registration will be allowed to register with standard use cases, but will receive the lowest tier of A2P messaging limits and will not qualify for the Political Special Use Case. In addition, you may be subject to penalties from carriers if political messaging traffic is incorrectly registered with standard use cases.

A2P 10DLC registration process

A2P 10DLC registration for Twilio ISVs is managed via the Twilio API. Optionally, you may register for A2P 10DLC using the Twilio Console, but the API is often preferable by ISVs due to the many clients that need to be registered. Registration can be divided into four main steps:

  1. Collect “Know Your Customer” (KYC) information about your  customers. 
  2. Register your company (the ISV).
  3. Register your customers. 
  4. Register messaging campaigns with the ‘Political’ special use case.

Political_ISV_10DLC_Quick_Reference_Guide_-_Trusthub_%2B_10DLC_%2B_SH_ST__1_.png

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There are two paths for registering your political customers:

1. Low Volume Standard Brands: Use the Low Volume Standard A2P 10DLC API or Twilio Console for your political customers who send fewer than 6,000 daily SMS and MMS messages over 10-digit long codes. The registration process for Low Volume Standard Brands is the same as that for Standard Brands, with the exception that the Low Volume Standard path skips secondary vetting (and the $40 secondary vetting fee). All 527 Political Organizations should use this path because with a Campaign Verify token, they: a) do not need secondary vetting, and b) will have messaging caps removed. 


2. Standard Brands: If you have 501(c) customers sending political messages who send more than 6,000 daily SMS segments and MMS messages, complete onboarding using the Standard A2P 10DLC APIs or Twilio Console. 

The process for A2P 10DCL Registration via the API is exactly the same for Low Volume Standard Brands and Standard Brands, with the exception that organizations registering for Low Volume will skip Secondary Vetting in Step 3.2. 

 

Step 1: Collect KYC information about my clients

1A. Before you begin the registration process for A2P 10DLC, you will need to have the relevant information on hand for each customer that you want to register:

  • Name
  • Physical Address 
  • Business Type (Your political customers will be Non-Profit)
  • Tax EIN 
  • Industry
  • Website
  • Regions of Operations
  • Point of Contact 
    • Name
    • Email
    • Title
    • Phone Number
    • Job Position (Director/VP/GM/General Counsel/CEO/CFO)

Note: Double Check that the EIN provided, Legal Company Name, and address match what is on tax documents. You can utilize the IRS’s list of Tax-Exempt Organizations or Registered Political Organizations to check. (It’s ok if your customer is not on this list, this is just a tool to double check or find information.)

 

1B. Additionally, All 527 political organizations will have to register with Campaign Verify before you register them for A2P 10DLC. You’ll need to collect the Campaign Verify tokens from your customers to use at the Brand registration step. 

Verification will involve submitting information about the political organization to Campaign Verify, as well as verifying the identity of an authorized person associated with the political organization. .

After completing verification with Campaign Verify, your customer will receive a Campaign Verify Token (CV token) that you will then use during A2P 10DLC registration. A full CV token is composed of 6 pipe (|) delimited fields, for example:

cv|1.0|tcr|10dlc|9957c339-d46f-49b7-a399-2e6d5ebac66d|GQ3NMEjED8xSlaAgRXAXXBUNBT2AgL-LdQuPveFhEyy

Listed below are some important pieces of information about CV tokens:

  • CV tokens expire after each election cycle and will need to be periodically updated. Tokens for verifications requests submitted to Campaign Verify prior to November 15, 2022 will be valid until January 31, 2023. A new cycle for verification requests will open on November 15, 2022. Tokens for verifications requests submitted on November 15, 2022 and later will be valid until January 31, 2025.
  • A single Campaign Verify token cannot be imported or used across multiple brands. If a 527 organization is a customer of multiple text messaging providers that will each create an A2P brand on their behalf, a unique CV token will need to be generated and provided to each vendor.

Step 2: Register Your Company (ISV) 

2A. First, you will need to create a Customer Profile for your company (the ISV) in the Twilio Trust Hub. Your Trust Hub Business Profile is your organization’s identity with Twilio and is necessary to begin A2P 10DLC registration.

Your Primary Customers profile should reflect your organization type:

  • If you are a nonprofit ISV that serves nonprofit and government clients, you should choose Non-profit Corporation as their Business Type and Not-for-Profit as their Business Industry .
  • If you are a for-profit ISV that serves nonprofit and government clients, you should choose the most appropriate Business Type for your company (e.g. Corporation, LLC)  and Business Industry (e.g. Technology). 

You will create your Primary Customer Profile using the Trust Hub UI in the Twilio Console.

Screen_Shot_2022-10-11_at_2.47.07_PM.png

Note: Before creating Secondary Customer Profiles for your end-customers, you must first register a top-level A2P 10DLC Brand as an ISV. This is completed in the Trust Hub UI of the Console as part of the 10DLC Onboarding Wizard.

2B. Second, you will create an A2P Brand for your ISV. Registration for the Primary A2P Brand for your organization as an ISV is also done using the Trust Hub UI in the Twilio Console. 

  • Go to the Trust Hub to create your Primary A2P Brand as an ISV
  • See these docs for more information on how to register your Primary A2P brand as an ISV.

Your Primary A2P Brand should reflect your Company Type.

  • For-Profit ISVs should choose Private (for private companies) or Public (for public companies) as their Company Type when registering their Primary A2P Brand based.
  • Nonprofit ISVs should choose Nonprofit as their Company Type when registering their Primary A2P Brand.

In this step, there are no additional requirements for ISVs with clients sending political messages. Importing the Campaign Verify token is only necessary in the next step when you register your customers who are 527 Political Organizations. 

Step 3: Register Your Customers and Verify Them for Political Messaging

In order to ensure your customers qualify for the Political Special Use Case, you will need to create a Secondary Customer Profiles for each of them and verify their A2P brand as a 527 organization or 501(c) nonprofit.

3A. First, you will need to create a Customer Profile for each of your customers. 

Complete Step 1 in the ISV Registration Walkthrough to create Secondary Customer Profiles for each one of your clients. Secondary profiles can also be created in Console, but because of their volume of customers, most ISVs opt to use the API. When using the API, The specifics of the attributes of the Secondary Customer Profile should reflect your clients’ organization types. 

  • Your customers (501(c) and 527 organizations) should have their Business Type set to Non-profit Corporation and their Business Industry set to NOT_FOR_PROFIT when calling the API in Step 1.3

Note: Double Check that the EIN provided, Legal Company Name, and address match what is on tax documents. You can utilize the IRS’s list of Tax-Exempt Organizations or Registered Political Organizations to check. (It’s ok if your customer is not on this list, this is just a tool to double check or find information.)

3B. The next step is to register your customers’ A2P Brand with carriers. Their A2P 10DLC brand registration tells carriers who your customers are, how their organization is incorporated (entity type), and unlocks the Political Special Use Case. 

Because political messaging may only be sent via a Standard Brand registration (not via Sole Proprietor Brand, formerly known as Starter Brand), all 527 Political customers should choose the Low Volume Standard Brand path when registering. 527s do not need Secondary Vetting because they have a Campaign Verify token and choosing the Low Volume registration will avoid the $40 Secondary Vetting fee. 527s with a valid CV token will not have daily message caps on T-Mobile. That is, they will be able to send over the 6,000 message daily threshold.  

Note: All 527 Political customers should choose the Low Volume Standard Brand path when registering. 527 Organizations do not need Secondary Vetting because they have a Campaign Verify token, and choosing the Low Volume registration will avoid the $40 Secondary Vetting fee. 527 Organizations with a valid CV token will not have daily message caps on T-Mobile. They will be able to send over the 6,000 message daily threshold. 

For 501(c) organizations, the specific U.S. tax exemption status, e.g. 501(c)(4), will be associated with their brand automatically during brand registration. 527 status will not be automatically detected and applied upon brand registration; importing the Campaign Verify token proves 527 status and activates the special A2P benefits for this entity type.

The organization status determines access to the Political Use Case that can offer higher throughput than Standard Use Cases. Therefore, it is very important that you provide accurate, consistent information when creating the business profile and registering the brand.

Complete Step 2 and Step 3 in the ISV Registration Walkthrough to create Secondary A2P Brands for each one of your clients. 

Your Secondary A2P Brands should reflect your clients’ company types.

  • 527 Political Organizations
    • 527 clients should have their Company Type set to ‘non-profit’ when calling the API in Step 2.3.3.
    • Secondary vetting is an additional brand review done by carriers that is unnecessary for 527 Organizations with a valid Campaign Verify Token. Please see instructions to skip Secondary Vetting in Step 3.2. 
    • Successfully registered 527 organizations (with a Campaign Verify token) will have the Political campaign use case unlocked.
  • 501(c) Customers 
    • Nonprofit customers should have their Company Type set to ‘non-profit’ in Step 2.3.3 when calling the ISV Registration API.
    • 501(c) customers registering as a Low Volume Brand should skip Secondary Vetting in Step 3.2. 
    • Successfully registered 501(c)4, (c)5, and (c)6 organizations will have the Political, Emergency, and Standard campaign use cases unlocked.
    • Successfully registered 501(c)3 organizations will qualify for the Charity and Emergency campaign use case.

3C. Import Campaign Verify Token to A2P Brand

Note: 527 Organizations must include their Campaign Verify Token during the Brand Registration Step. Please Review Registration for 527 Political Organizations.

A 527 organization that does not register with Campaign Verify and provide a token during 10DLC registration will be allowed to register with standard use cases, but will receive the lowest tier of A2P messaging limits and will not qualify for the Political Special Use Case. In addition, you may be subject to penalties from carriers if political messaging traffic is incorrectly registered with standard use cases. You must import your Campaign Verify token during the Brand Creation step.

Complete Step 3.3 to Import the Campaign Verify Token to your Customers Brand. Check that the import vetting was successful using this endpoint in Step 3.4. Look for a vetting status of “SUCCESS”

3D. There are some cases where carriers cannot automatically verify your customers status and action is needed on your part. You can use the GET command to check the status of your brand registration.  In addition to having the status APPROVED, you’ll want to ensure that your 501(c) customers were successfully verified as such (the parameter tax_exempt_status returns the correct 501(c) type). You can also verify if Brand registration was successful in Console. 

Screen_Shot_2022-10-11_at_3.00.19_PM.png

If your brand was not verified please take the following steps: 

501(c) Organizations:  You can send an email directly to 10dlc-onboarding@twilio.com to initiate a manual review by providing the following information:

Email Subject line: Tax Exempt Verification - <Customer Name>

  • Nonprofit Entities should provide:
    • Account SID: The Twilio Account SID that houses the A2P brand in question
    • Brand Friendly Name: The friendly name of the brand as it appears in the Twilio Console or the API
    • Supporting Documentation: An IRS nonprofit determination letter or Tax Form 990 from the latest tax year, that has been filed and accepted by the IRS. If not already accessible to you, we encourage you to use the IRS Tax Exempt Organization Search to find your entity’s qualifying tax-exempt status documentation.

Before sending the email to our support team, please verify the following:

  • You have already registered your A2P brand
  • The A2P brand was registered with the “Nonprofit” company type

527 Political Organization: As long as a 527 political organization has successfully imported a valid Campaign Verify Token, there should not be an issue with A2P Brand registration.

Step 4: Register Messaging Campaigns with the Political Special Use Case

Any traffic that meets the definition of political messaging should be registered with the Political Special Use Case, the Political Special Use Case is unlocked for your customers who are verified political campaigns, parties, PACs (527 Organizaions), and advocacy organizations (IRS 501(c)(4)s, 501(c)(5)s, 501(c)(6)s). 

Note: Political Messaging is defined as part of an organized effort to influence decision making of a specific group.

Note: 501(c)(3)s do not qualify for the Political Special Use Case. 501(c)(3)s doing civic engagement should register with Charity Special Use Case.

4A. In this step, you’ll register your customers’ Messaging Campaign Use Cases. Each of your end-customers’ registered Brands is linked to a Twilio Messaging Service. You’ll need at least one Twilio Phone Number inside of a Messaging Service to complete Use Case registration. After connecting your campaign to a Messaging Service, you’ll select the Political Use Case, and provide some additional context on your campaign including a description and sample messages.

An A2P Brand may have one or more Messaging Campaigns. However, the registration process is the same for each campaign Use Case that you create:

  • You will need to register campaigns under all your customers' Brands to complete 10DLC registration on their behalf. Complete Step 4 and Step 5 in the ISV Registration Walkthrough to register campaigns on behalf of your clients.
  • When calling the API in Step 5.1 to Fetch possible A2P campaign Use Cases, note that the Use Cases returned will only be the Use Cases for which your client’s brand qualifies (“political” or “charity”). This will help you ensure that you select a Use Case that will be successfully registered in Step 5.2, Create A2P Messaging campaign use case.

Be sure to use the correct Brand Registration SID of the target brand that you’d like to associate the campaign with when querying possible A2P campaign use cases, and creating the use case. 

Getting Started

Now that you’ve reviewed the main steps for Political ISVs to register for A2P 10DLC, it’s time to get started! You can visit the ISV Onboarding Guide guide below for the complete step-by-step instructions.

START A2P REGISTRATION NOW

 

 

 

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