Notice: Resellers of Japanese Phone Numbers must provide valid Telecommunications Numbering Use Plan (TNUP) (November 2022)

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 Telecommunications numbering use plan (TNUP) has been authorized by MIC
  • 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 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 resell Japanese phone numbers, but do not have a valid TNUP authorized by MIC, we encourage you to seek your own legal advice on how to secure the same as soon as possible. Please note that in order for MIC to authorize your TNUP, you must either be a Registered Telecom Business Operator or Notified Telecom Business Operator. 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, please keep a copy, and be prepared to submit it to Twilio. We will send you instructions on how to submit a copy of the TNUP to us at a later date.

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 and have a TNUP approved by MIC. 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.

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