New Changes to A2P 10DLC Starter Brands FAQ

The Basics (What, When, Why, etc)

What is happening?

Twilio is retiring Starter Brand registrations for A2P 10DLC messaging. Effective immediately, you should no longer submit new Starter Brand registrations. 

The new Low Volume Standard Brand should be used if you have a tax ID (typically an Employee Identification Number, or EIN) and low traffic requirement (less than 6,000 messages per day). Low Volume Standard Brands can be used for mixed messaging campaigns with multiple use cases, multiple numbers per campaign, higher throughput and lower filtering than current Starter Brands.  If you do not have a tax ID, we’ll be introducing a new form of Sole Proprietorship Brand soon as another alternative to Starter Brands.

Starting September 28, 2022 a new Low Volume Standard Brand registration will be available for a one-time fee of $4 USD. Campaign registration fees, formerly charged at $50 per campaign setup, will be waived. (Note that Standard Brand and campaign registrations were previously available for $94 USD.)

Your existing Starter Brands can remain registered, but will need to meet the following new guidelines by November 3, 2022:

  • No Tax ID: Customer brands that have a tax ID are not eligible for Starter Brands - use a Low Volume Standard Brand instead.
  • Valid Details: Starter Brands must include a valid and accurate business name, first name, last name, email address, phone number, and physical address. 
  • Limited Brands Per Validation: Each phone number can only be used to validate up to 3 brands (including brands registered outside of Twilio). Each email or physical address can only be used to validate up to 10 brands (including brands registered outside of Twilio). 
  • US and Canada Addresses: Only valid U.S. or Canadian addresses (including P.O. boxes) are allowed. Addresses in other countries are no longer permitted.
  • Limited Campaigns and Phone Numbers: A Starter Brand can only be tied to one campaign and one phone number.

Existing Starter Brands that don’t meet these new guidelines are subject to removal by Twilio after November 3, 2022.

These changes impact every provider registering US A2P 10DLC brands via The Campaign Registry (TCR), including Twilio. For more information, please review our blog post about changes to Starter Brands.

When is it happening (high level timeline)?

September 27, 2022

External communication to the customers

October 4, 2022

Block new starter brand registration 

November 3, 2022

Start existing starter bands cleaning process

 

Why are these deadlines so close?

These deadlines are set and enforced by TCR across the industry. 

Why is it happening?

Twilio Starter Brands was based on what the TCR termed Sole Proprietor Brands. TCR is rolling out new requirements for a second version of the Sole Proprietor Brands, but this will require time to define and build those changes, so we’re pausing new starter registrations.

Sole Proprietor Brands (known to Twilio customers as Starter Brands) are intended for hobbyists and small or individual businesses without an Employer Identification Number (EIN) or Federal tax registration number. The changes being implemented by TCR are in line with broader industry goals to drive a verified business communications ecosystem through registration and verification.

Why is it happening now, what prompted the change?

TCR partnered across the industry and announced new requirements recently that led to these changes to Twilio’s Starter offering.

Alternatives to Starter Brands

Low Volume Standard:

What is the best alternative to Starter Brands? 

“Low Volume Standard” brands for customers of ISVs who have an EIN and anticipate sending <6K messages  per day. Toll free senders remain an alternative to US A2P 10DLC for businesses who do not require a local sender. 

What is a Low Volume Standard registration?

Low Volume Standard is a Standard Brand registration with a Low volume campaign that skipped secondary vetting.

Customers can use the Standard Brand registration documentation for the API: https://www.twilio.com/docs/sms/a2p-10dlc/onboarding-isv

This article covers more detail about the sec vetting: https://support.twilio.com/hc/en-us/articles/4403988619163-Secondary-Vetting-for-A2P-10DLC

This article covers information about the existing Standard Brand campaign types and pricing involved: https://support.twilio.com/hc/en-us/articles/1260803965530-What-pricing-and-fees-are-associated-with-the-A2P-10DLC-service-

Is there any documentation on how logistically customers will register all of their existing starter brands as standard? Would this be just essentially starting from scratch and using the standard API and then deleting all of their starter brands?

The process will be the same as registering from scratch with Standard APIs for ISV customers.

Yes, customers can register for Low Volume Standard brand and then Twilio will delete the starter brands after November 3, 2022

What about secondary vetting - are we waiving that cost as well?

The customer needs to consciously opt out of secondary vetting if they'd like to avoid the additional fee. They can do the sec vetting if they'd like the trust score and the higher benefits as a result

Twilio is not changing anything about the sec vetting options or pricing for ISV customers using the API. We are just making it clear to customers that they can save on costs if they are fine with the low volume campaign limits

What are the brand and campaign limits for Low Volume Standard?

Campaigns and Phone number limits for Low Volume standard are the same as standard brands:  there is a 50 campaign limit per use case type and 400 phone number limit per messaging service. Both can be lifted by reaching out to support

How many Phone Numbers can be associated with a Standard Campaign? How do Low Volume Standard compare to the original Starter Brand offering?

This document provides a good comparison for Low Volume Standard vs Starter and the limits: https://support.twilio.com/hc/en-us/articles/4407882914971-Comparison-between-Starter-Low-Volume-Standard-and-Standard-registration-for-A2P-10DLC

Are there any plans of lowering registration time for Low Vol Standard?

No. Brand registration response is asynchronous but usually instant approval for Low Volume Standard Brands since Secondary Vetting is skipped.

At what level does this 6K traffic per day is enforced for Low Volume Standard?

The 6K per day message segment limit is enforced at EIN level. This EIN limit is enforced by carriers, if a customer with an EIN and has registered a brand with Twilio and also with our competitors, the enforcement will be considered collectively.

Will the existing 10DLC registration APIs still need to be updated to support the “low volume” standard brand registration?

The "Low Volume Standard" brand is just a new name for a Standard brand without Secondary Vetting. ISV and Direct customers already have the option of creating new Standard brands with skipping secondary vetting. Per the advisory, you’ll be able to see the campaign fee of $50 not be applicable starting Sep 28.

Will there be an option for standard brands to downgrade to low volume?

The ecosystem does not have upgrade or downgrade options available today. Customers would be able to re-register for appropriate campaigns and move over their Phone Numbers at any time. In addition, the only pricing difference between Standard brands and Low Volume Standard Brands is the one-time $40 vetting fee, which Standard customers have already paid upon registration. Downgrading offers no financial benefit and yet decreases the messaging capability.

What campaign use case do Low Volume Standard Brands have access to?

We recommend customers to go with the low volume mixed use case. Technically, Low Volume Standard Brands have access to all types of standard campaigns (marketing, 2FA, etc.), but all of them default to the daily limit and rate limits of the Low Volume Standard Brand. For example, a Marketing campaign registered under a regular Standard Brand has a minimum throughput of 12 across US carriers. But, a Marketing campaign registered under a Low Volume Standard Brand will default to the Low Volume Standard Brand's throughput limit, which is 3.75 across US carriers (see here). Starting Nov. 3rd, the monthly fees for Low Volume Mixed campaigns will decrease from $2 to $1.5 while other campaign fees remain unchanged, making it the most economical option for customers with Low Volume Standard Brands.

How Standard registration for US A2P 10DLC  and Toll Free senders compared to each other?

Here is a comparison chart that can help customers decide

 

A2P 10DLC (local)

Toll Free

Features

Availability

YES

YES

Message throughput range (MPS)

3-180 MPS

Additional throughput based on TCR Trust Score

3-150+ MPS 

Additional throughput based on additional verification process

Message Volume Limit

Yes

10,000 - 200,000 daily

No

Unlimited

Voice Support

Yes

Yes

Registration

Provisioning time

Instant

Instant

A2P registration time

Instant approvals except for post-approval campaigns

3+ Weeks right now

Provisioning

experience

- Console

- API

- Console

- API

Compliance registration experience

- Console

- API

- Manual + Support

- Bulk + Support

- Console (in development)

- API (in Pilot)

Compliance requirements

High

- KYC

- Use case

- TCR validation

- Opt in workflow

High

- KYC

- Use case

- Opt in workflow

- All reqs

- TFN (subject to limits)


From Q4 ‘22

- Mandatory for all Toll-Free numbers

Pricing

Registering fee is different for Starter vs standard

$1 rental fee per month


Fees for A2P registration

Registration is free 

$2 rental fee per month


Fees for MPS beyond 3

Carrier Fees

Yes

Yes

Key capabilities

 

-High throughput

-No verification cost

 

What are the pros and cons of using toll free?

Pros:

  • Toll Free verification is free, unlike A2P
  • Customers can currently send up to 2k messages/day on an unverified TFPN. That number will ratchet down over the next 6 months
  • Customers who submit their TFPN for verification get >2k/day and less filtering than unverified

Cons:

  • There is a long backlog to get verified after submission. It’s ~6 weeks at this point. This timeline fluctuates and the Messaging Compliance API does not affect this. But, customers CAN send while  TFPN is unverified or pending - see Pros above.
  • Messaging Compliance API is in Pilot right now and will go into Private Beta next. So, it’s not open to everyone, yet. Customers who aren’t in Pilot or Private Beta will need to submit manually through Support.

Pricing and Fees

What is the registration and runtime pricing for Low Volume Standard and Standard? 

No difference in runtime pricing.

 

Low Volume Standard

Standard

Brand Registration (One Time)

$4

$4

Secondary Vetting

-

$40

Campaign Registration (One Time)

$0 (used to be $50)

$0 (used to be $50)

Campaign Monthly Fees

$1.5* for low volume mixed use case (used to be $2)

*Effective from Nov 3

$1.5* - $10 depending on use case

https://support.twilio.com/hc/en-us/articles/1260803965530-What-pricing-and-fees-are-associated-with-the-A2P-10DLC-service-

General Guidance:

How should customers change their onboarding and API flow given this change?

Customers will no longer be able to create new Starter Business Profiles or Brands via our Console and API from October 4, 2022. Previously, the “Low Volume Standard” brand option (i.e., skip secondary vetting) was only available to ISV customers. Going forward, we will allow direct customers to access this option via Console, as well.

Separately, there will be changes around the registration process for all new campaign registrations, where additional information around customers’ opt-in message flow and how they handle opt-out requests from end users will be required. This change is orthogonal to the Starter Brand changes. We will share information with customers regarding this change in the upcoming weeks.

How do I register my customers who do not have an EIN for 10DLC?

Existing Starter Brands and campaigns that pass the audit will not be impacted (they may be impacted by future changes within the industry).

To register new customers who do not have a Tax ID/EIN, we encourage you to explore using Toll Free numbers. Messages sent through unregistered 10DLC numbers will be subject to unregistered fees and risk of higher filtering. Twilio is working with the industry to introduce another registration type to replace Starters, but there we cannot publish a timeline for this capability yet."

Who is impacted by this change?

New and existing customers who want to register a new Starter Brand are impacted. Existing Starter Brands and Campaigns that meet the new requirements will not immediately be impacted by these changes.Any existing brands that fail to meet the criteria will be deleted on behalf of the customers by Twilio on November 3, 2022. We’ll communicate any future impacts as we get more clarity on it.

Is this industry wide?

Yes, these changes for "Sole Prop 2.0" from TCR will impact every provider registering US A2P 10DLC brands. 

Meeting the New Criteria and Deletion:

What is the new criteria that will be used for the Twilio audit of existing Starter Brands?

The criteria is as laid out in our advisory:

  • Tax ID (EIN) Requirement: New and existing customer brands that have a Tax ID (EIN) are not eligible for Starter Brands. They’ll be required to register for Low Volume Standard Brands.
  • Valid Details: Starter Brands must include a valid business name, first name, last name, email address, phone number, and physical address. These fields should contain accurate information.
  • Limited Brands Per Validation: Each phone number can only be used to validate 3 or fewer brands. Each email or physical address can only be used to validate 10 or fewer brands. This limit applies for all A2P registrations within the ecosystem, even externally-registered brands outside of Twilio.
  • US and Canada Addresses: Existing Starter Brands with valid U.S. or Canadian addresses are allowed. International addresses outside of these countries in Starter Registrations will be deleted.
  • Limited Campaigns and Phone Numbers: Only one campaign and one phone number is allowed per Starter Brand.

Twilio has sent a follow-on targeted communication to customers with information about their account and number of brands that are failing these checks. Customers will not have a way to update this information for brands that are non-compliant with the new criteria.

It seems that non-US businesses can't register for A2P 10DLC? What if a EU based customer wants to send traffic to the US is that doable?

Non US/CAN businesses will no longer be allowed to register for the Sole Proprietor entity type (called Starter Brands by Twilio until now). Standard brands are still an option for these customers.

Do I understand correctly that existing Starter brands won't be affected if they meet the new requirements (business name, first name, last name, email address, phone number, and physical address)?

If existing registrations meet the complete criteria laid out in the advisory and this wiki, including EIN, duplication, obfuscation, etc, they would not be immediately impacted. TCR might still be making some changes to the Sole Proprietor entity type that could have an impact later for existing registrations too - we will share once we know more.

Starting on the deadline (Nov 3) will any 'incorrectly' registered starter brands/numbers be considered unregistered? Meaning they'll incur fines and possibly filtering?

After the deadline of Nov 3, Twilio will begin deleting incorrect registrations that have been identified for each customer. Upon deletion of these brands, any Phone Numbers associated with these brands would be considered unregistered and incur higher unregistered fees and possible filtering. Customers can avoid this by moving their traffic to Standard Brand registrations before the deadline.

Relaunching Starters:

Do we / when do we expect to unpause Starter Brands registrations? 

As the changes to Sole Proprietorship Registration directly impacts Twilio Starter Brands, we will need to ensure any new registration is in accordance with TCR requirements. We are still working though the plan, to ensure customers meet these requirements and we will announce the date of reopening Starter registration as we define our roadmap. 

What will be the difference between the current starter and new starter brand? Can a customer wait until a new starter is available to make any changes?

Twilio does not have a firm plan in place for a "new starter". Our recommendation for customers is to use the Standard Registration campaign types, as appropriate. We'll communicate any such details with customers in the future (where applicable).

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