Before December 31, 2022, all resellers of Japanese Phone Numbers must provide Twilio with their valid Telecommunications Numbering Use Plan (TNUP). This guide explains the requirements in detail, and what our customers need to do.
Notice: Under Japanese law, you are likely to be considered a reseller of Japanese phone numbers if you are not the end-user of the phone number. This would include cases where you provision Japanese phone numbers to your customers, or provide wholesale services to other licensed telecommunications operators in Japan.
What is happening
On September 8, 2022, the Japanese Ministry of Internal Affairs and Communications (MIC) amended the Telecommunications National Numbering Plan. As a result of these amendments, Twilio is legally required by December 31, 2022 to:
- Verify that resellers have a valid TNUP
- Impose contractual obligations on resellers to comply with relevant telecommunications regulations, including Know Your Customer (KYC) obligations.
In the coming weeks, Twilio will be sending customers with Japanese Phone Numbers instructions on how to submit a copy of their valid TNUP, along with the relevant telecommunications regulatory obligations, including KYC compliance requirements that will need to be agreed to.
What do you need to do?
If you are unsure of your reseller status, or if you are a reseller and do not hold a valid telecommunications license or TNUP, you are encouraged to seek legal advice and assistance on obtaining a telecommunications license and valid TNUP. A TNUP may need to be approved by MIC to be valid. The requirement for resellers to be a registered or notified business operator is not a new requirement.
You can find additional resources on MIC’s website:
After obtaining the authorization of your TNUP from MIC, you'll need to complete the following:
- Download the application form from the regulatory guidelines page and complete all sections.
- Create a new regulatory bundle from their parent account - one for each phone number type that they intend to resell use i.e., National or Toll Free.
- Name the bundle as a Reseller Bundle
- Upload a copy of the completed Application (appended with the TNUP), along with other reseller details and supporting documentation as outlined in the Japan Regulatory Guidelines.
Note: Each TNUP contains a section listing who a company's wholesale partners are. This section needs to list Twilio Japan GK (not Twilio Inc).
For additional guidance, see How to Submit a Japanese Phone Number Regulatory Bundle Application.
Foreign companies can also provide a National/Toll-Free number as a reseller. "Reseller Bundle" should be submitted with the reseller's information, while the regular Bundle for assigning a number requires the information of an end user with an address in Japan.
What happens if you don't take action?
Your services using Japanese phone numbers may be impacted on January 1, 2023 if you do not:
- Provide Twilio with a copy of your valid TNUP; and
- Agree to comply with relevant telecommunications regulations, including KYC requirements
Frequently asked questions
Q: How do you define a customer who is a reseller of Japanese phone numbers?
A: Under Japanese law, you are likely to be considered a reseller of Japanese phone numbers in cases where you are not the end-user of the phone number. This would include cases where you:
- provision Japanese phone numbers to your customers; or
- provide wholesale services to other licensed telecommunications operators in Japan.
Q: Will customers who are not incorporated in Japan lose their ability to resell Japanese numbers?
A: Companies who are not incorporated in Japan should be able to become a Registered Telecom Business Operator or Notified Telecom Business Operator. Additional information can be found on MIC’s website, here.
Q: Can Twilio obtain a Telecom Business Operator registration or notification or TNUP on behalf of our customer?
A: No, Twilio cannot obtain a Telecom Business Operator registration or notification or TNUP on behalf of our customers.
Q: What are the ways to submit the TNUPs?
A: By December 31, 2022, Resellers of Japanese phone numbers must
- Download the application form from the regulatory guidelines page and complete all sections.
- Create a new regulatory bundle from their parent account (one for each phone number type that they intend to resell use i.e., National or Toll Free), name the bundle as a ‘Reseller Bundle’ and upload a copy of the completed Application (appended with the TNUP) along with other reseller details and supporting documentation as outlined in the Japan Regulatory Guidelines. Each TNUP contains a section listing who a company's wholesale partners are. This section needs to list Twilio Japan GK (not Twilio Inc).
Q: What resources can help explain the requirement for a valid TNUP
A: Customers can find additional information on MIC’s websites on Telecommunications licensing, and TNUP.
Q: Can Twilio refer me to a local law firm specializing in these matters?
A: Regrettably, Twilio is not able to refer our customers to law firms.
Q: Do I need a TNUP for each number type I resell?
A: You usually need a TNUP for each type of number you resell.
Q: When does a TNUP need to be approved by MIC to be valid?
A: If you only resell Japanese national, mobile or toll free numbers you are unlikely to need approval by MIC of the TNUP. In the event that you resell Japanese local numbers (0ABJ) you are likely to need your TNUP approved by MIC.
Q: What if I resell Japanese local numbers (0ABJ) and national, mobile or toll free numbers does a TNUP need to be approved by MIC to be valid?
A: If you resell Japanese local numbers (0ABJ) and also resell Japanese national, mobile and/or toll free numbers you are likely to need approval by MIC of each TNUP for the number type(s) you resell.
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