A2P Rules & Regulations V1.0
Why is A2P here?
A2P 10DLC is designed to increase trust across the messaging ecosystem. One part of creating this trust in SMS messaging relates to registration to provide transparency about who is sending messages and what types of messages they are sending. The other part of building trust is ensuring that people have provided consent for that messaging. User consent to receive messages is not just good practice, it is required by carriers and Twilio’s messaging policies.
The Cellular Telecommunications Industry Association (CTIA), the trade association representing wireless carriers in the U.S., released the latest version of its messaging principles and best practices. This document outlines messaging practices that facilitate a healthy messaging ecosystem of wanted messages between businesses (and nonprofits) and consumers. Among key tenets of these principles and best practices are obtaining explicit opt-in and honoring opt-out from the people you are messaging. This opt-in must relate not only to your organization as the sender but the specific campaign use case for which you are messaging.
U.S. carriers determine what messages are delivered to their customers, the end consumer. Failure to abide by the CTIA messaging principles and best practices can result in message filtering and phone number blocking by carriers.
Below, I will provide the full policies for Twilio & PushPress Grow phone systems, however, I summarized the 8 key takeaways from both platforms that we must all be aware of.
10 Key takeaways on the entire policy that you need to be aware of:
A common misconception we will most likely encounter, is that our Grow clients will assume that they are registered and ALL messages should be going through.
This is not the case and in fact, we will probably encounter more message failures and filtering going forward.
Due to Grow clients’ failure to follow the specific best practice rules set below.
Not all messaging will go through! - The process will go through a computer filtering database and sometimes we won't have a clear understanding on why messaging is failing. CX should look to see if the Grow client is following best practices as outlined below in the following 9 steps
Twilio Clients can now only send 6,000 SMS messages per day (2,000 to T-Mobile Carriers)
Can a client get higher limits? YES - But this will require a new registration use case, and a higher monthly cost of $44/month to upgrade to 6,000+ messaging
PushPress Grow-Phone rules
Every new sub-account on the PushPress Grow - Phone System going forward will follow the "Ramp Up Model". this will help “Warm up the trust score”
The is multiplied each day by the number of days (till the 7th day) the location has spent with us. Starting the 8th day the location will have the limit set to 5000 SMS/day. Below is the table which will give you a detailed idea:
SMS limit
Day Limit [SMS] 1 250 2 500 3 750 4 1000 5 1250 6 1500 7 1750 8th Day & Ongoing 5000
Per Twilio and PushPress Grow phone rules, Our gyms will be allowed a 1% unsubscribe rate before they get suspended
Consent (“opt-in”) must be provided on EVERY new message
Revocation of Consent (“opt-out”) must be given on EVERY New message
Sender Identification that clearly identifies “who” and from “what” business is sending the message.
This is going to be a significant shift in how our Grow clients communicate with their gym members. Most of our Grow clients want a sense of “Community” in the facility. Therefore, interacting with clients and having to clearly ID themselves as the Coach and Business name in their messaging will be a significant shift in their best practices.
This will be something our internal teams need to remember as well when building out workflows to incoming leads and members.
EXAMPLE of a compliant message sequence:
Message 1 (opt-in and Opt-out)
“You have successfully opted-in to receive SMS messages from {{location.name}}. Messaging frequency may vary. Reply STOP at any time to opt-out. Message & Data rates may apply.”
Should we go back to all gyms and add this?
Message 2 (Sender ID) ”Hi John, this is Dave from PushPress. I just wanted to check in with you. I haven’t seen you in class in a few days. Is everything ok?”
Sender ID, opt in and opt out, is not required for ongoing messages in the same conversation. With that said, best practices suggest that if 1 day or more has elapsed in the conversation, the business should clearly ID themselves and the business again.
EXAMPLE: Long-term lead nurture where the person opted in on day 1, but 30 days or more later the business is still sending SMS - Then best practices states you should be sending messages identifying your name and business as well as clear directions on how to opt-out.
GOOD MESSAGE: ”Hey Tim, this is Dave from PushPress Gym. I just wanted to say we miss you in classes and hope to get you back soon. How can we help keep you motivated?”
BAD MESSAGE: ”Hey Tim, we saw you haven’t been to class lately. Do you need more motivation?”
Messaging Usage:
Anything that is illegal in the jurisdiction where the message recipient lives. Examples include, but are not limited to:
Cannabis (This includes CBD!). Messages related to cannabis are not allowed in the United States as federal laws prohibit its sale, even though some states have legalized it. Similarly, messages related to CBD are not permissible in the United States, as certain states prohibit its sale. Twilio defines a cannabis message as any message which relates to the marketing or sale of a cannabis product, regardless of whether or not those messages explicitly contain cannabis terms, images, or links to cannabis websites.
Prescription Medication. Offers for prescription medication that cannot legally be sold over-the-counter are prohibited in the United States.
Hate speech, harassment, exploitative, abusive, or any communications that originate from a hate group.
Fraudulent messages.
Malicious content, such as malware or viruses.
Filtering Evasion:
Content designed to evade detection. We do not allow content which has been specifically designed to evade detection by unwanted messaging detection and prevention mechanisms. This includes intentionally misspelled words or non-standard opt-out phrases that have been specifically created with the intent to evade these mechanisms.
Trust Scores:
Carriers will be assigned “Trust scores” to businesses and their messaging. If they find that a brand is not following best practices and seems “Spammy” this could result in all the SMS becoming filtered and blocked.
This is similar to an email list and “Warming it up” if people are interacting with the messaging and not “Opting out” repeatedly then the carriers will start to “Trust the brand” and assume they are providing valuable content. On the flipside, if a brand is continuously getting opt outs and complaints, the carriers will put a lower trust score on the brand and could lead to full message blockage
There is a 1 time registration cost of $16.54 to register for A2P registration to every client.
If a campaign or brand fails for any reason, a new registration is required and another $16.54 fee will be assessed for every subsequent registration.
There is now an ongoing $4 per-month fee to have A2P
POLICIES FOR TWILIO AND PUSHPRESS GROW PHONE -
Twilio’s Messaging Policy
Last Updated: March 14, 2022
This Messaging Policy applies to SMS, MMS, Chat, and WhatsApp messaging channels.
This principle is central to Twilio's Acceptable Use Policy.
Twilio Messaging
Twilio treats all messaging transmitted via Twilio’s platform - regardless of use case or phone number type (e.g., long code, short code, or toll-free) - as Application-to-Person (A2P) messaging. All A2P messages originating from Twilio are subject to this Messaging Policy, which covers rules and /or prohibitions regarding:
Consent ( “opt-in”);
Revocation of Consent (“opt-out”);
Sender Identification;
Messaging Usage;
Filtering Evasion; and
Enforcement.
This policy applies to all customers who use Twilio’s messaging channels. If you provide your own end users or clients with the ability to send messages through Twilio, for example as an ISV (Independent Software Vendor), you are responsible for the messaging activity of these users. You must ensure that any messaging activity generated by your users is in compliance with Twilio policies.
Consent / Opt-in
What Is Proper Consent?
Consent can't be bought, sold, or exchanged. For example, you can't obtain the consent of message recipients by purchasing a phone list from another party.
Aside from two exceptions noted later in this section, you need to meet each of the consent requirements listed below. If you are a software or platform provider using Twilio’s platform for messaging within your application or service, you must require your customers to adhere to these same requirements when dealing with their users and customers.
Consent Requirements
Prior to sending the first message, you must obtain agreement from the message recipient to communicate with them - this is referred to as "consent", you must make clear to the individual they are agreeing to receive messages of the type you're going to send. You need to keep a record of the consent, such as a copy of the document or form that the message recipient signed, or a timestamp of when the customer completed a sign-up flow.
If you do not send an initial message to that individual within a reasonable period after receiving consent (or as set forth by local regulations or best practices), then you will need to reconfirm consent in the first message you send to that recipient.
The consent applies only to you, and to the specific use or campaign that the recipient has consented to. You can't treat it as blanket consent allowing you to send messages from other brands or companies you may have, or additional messages about other uses or campaigns.
Proof of opt-in consent should be retained as set forth by local regulation or best practices after the end user opts out of receiving messages.
Alternative Consent Requirements
While consent is always required and the consent requirements noted above are generally the safest path, there are two scenarios where consent can be received differently.
Contact initiated by an individual
If an individual sends a message to you, you are free to respond in an exchange with that individual. For example, if an individual texts your phone number asking for your hours of operation, you can respond directly to that individual, relaying your open hours. In such a case, the individual’s inbound message to you constitutes both consent and proof of consent. Remember that the consent is limited only to that particular conversation. Unless you obtain additional consent, don't send messages that are outside that conversation.
Informational content to an individual based on a prior relationship
You may send a message to an individual where you have a prior relationship, provided that individual provided their phone number to you, and has taken some action to trigger the potential communication, and has not expressed a preference to not receive messages from you. Actions can include a button press, alert setup, appointments, or order placements. Examples of acceptable messages in these scenarios include appointment reminders, receipts, one-time passwords, order/shipping/reservation confirmations, drivers coordinating pick up locations with riders, and repair persons confirming service call times.
The message can't attempt to promote a product, convince someone to buy something, or advocate for a social cause.
Periodic Messages and Ongoing Consent
If you intend to send messages to a recipient on an ongoing basis, you should confirm the recipient’s consent by offering them a clear reminder of how to unsubscribe from those messages using standard opt-out language (defined below). You must also respect the message recipient’s preferences in terms of frequency of contact. You also need to proactively ask individuals to reconfirm their consent as set forth by local regulations and best practices.
Identifying Yourself as the Sender
Every message you send must clearly identify you (the party that obtained the opt-in from the recipient) as the sender, except in follow-up messages of an ongoing conversation.
Opt-out
The initial message that you send to an individual needs to include the following language: “Reply STOP to unsubscribe,” or the equivalent using another standard opt-out keyword, such as STOPALL, UNSUBSCRIBE, CANCEL, END, and QUIT.
Individuals must have the ability to revoke consent at any time by replying with a standard opt-out keyword. When an individual opts out, you may deliver one final message to confirm that the opt-out has been processed, but any subsequent messages are not allowed. An individual must once again provide consent before you can send any additional messages.
Usage Limitations
Content We Do Not Allow
The key to ensuring that messaging remains a great channel for communication and innovation is preventing abusive use of messaging platforms. That means we never allow some types of content on our platform, even if our customers get consent from recipients for that content. Twilio’s Acceptable Use Policy prohibits sending any content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses a threat to the public, even if the content is permissible by law. Other prohibited uses include:
Anything that is illegal in the jurisdiction where the message recipient lives. Examples include, but are not limited to:
Cannabis. Messages related to cannabis are not allowed in the United States as federal laws prohibit its sale, even though some states have legalized it. Similarly, messages related to CBD are not permissible in the United States, as certain states prohibit its sale. Twilio defines a cannabis message as any message which relates to the marketing or sale of a cannabis product, regardless of whether or not those messages explicitly contain cannabis terms, images, or links to cannabis websites.
Prescription Medication. Offers for prescription medication that cannot legally be sold over-the-counter are prohibited in the United States.
Hate speech, harassment, exploitative, abusive, or any communications that originate from a hate group.
Fraudulent messages.
Malicious content, such as malware or viruses.
Any content that is designed to intentionally evade filters (see below).
Country-Specific Rules
All messages should comply with the rules applicable to the country in which the message recipient lives, which can be found in our Country-Specific Guidelines. Additionally, Twilio has Country Specific Requirements for select countries, which you should review prior to sending a message to recipients in or from those countries.
Age and Geographic Gating
If you are sending messages in any way related to alcohol, firearms, gambling, tobacco, or other adult content, then more restrictions apply. In addition to obtaining consent from every message recipient, you must ensure that no message recipient is younger than the legal age of consent based on where the recipient is located. You also must ensure that the message content complies with all applicable laws of the jurisdiction in which the message recipient is located or applicable communications industry guidelines or standards.
You need to be able to provide proof that you have in place measures to ensure compliance with these restrictions.
Messaging Policy Violation Detection and Prevention Evasion
Customers may not use the Grow platform to evade a telecommunications provider’s unwanted messaging detection and prevention mechanisms. Subject to Twilio’s Privacy Notice, Twilio collects and monitors the content of text messages that are transmitted via Twilio’s platform to certain countries in order to detect spam, fraudulent activity, and violations of Twilio's Acceptable Use Policy. For more information on the collection and monitoring of text message content in certain countries, please review Twilio’s Country Specific Requirements, which are part of Twilio’s Acceptable Use Policy.
Examples of prohibited practices include:
Content designed to evade detection. As noted above, we do not allow content which has been specifically designed to evade detection by unwanted messaging detection and prevention mechanisms. This includes intentionally misspelled words or non-standard opt-out phrases which have been specifically created with the intent to evade these mechanisms.
Snowshoeing. We do not permit snowshoeing, which 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.
PushPress Grow - Phone Messaging Policy
All messaging transmitted via the platform - regardless of use case or phone number type (e.g., long code, or toll-free) - need to comply with the Application-to-Person (A2P) messaging. All A2P messages originating from the system are subject to this Messaging Policy, which covers messaging rules and /or prohibitions regarding:
Consent (“opt-in”): Consent can't be bought, sold, or exchanged. For example, you can't obtain the consent of message recipients by purchasing a phone list from another party. And SMS should only be sent to the opted-in contacts.
Revocation of Consent (“opt-out”): The initial message that you send to an individual needs to include the following language: “Reply STOP to unsubscribe,” or the equivalent so that Individuals have the ability to revoke consent at any time by replying with a standard opt-out keyword.
Sender Identification: Every initial message you send must clearly identify you (the party that obtained the opt-in from the recipient) as the sender, except in follow-up messages of an ongoing conversation.
Messaging Usage: You should not be sending messages in any way related to alcohol, firearms, gambling, tobacco, or other adult content.
Filtering Evasion: As noted above, we do not allow content that has been specifically designed to evade detection by unwanted messaging detection and prevention mechanisms. This includes intentionally misspelled words or non-standard opt-out phrases which have been specifically created with the intent to evade these mechanisms. We do not permit snowshoeing, which 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.
This policy applies to all customers who use PushPress Grow - Phone messaging services to safeguard their messaging capabilities and services.
How We Handle Violations?
When we identify a violation of these principles, where possible, we will work with customers in good faith to get them back into compliance with the messaging policy. However, to protect the continued ability of all our customers to freely use messaging for legitimate purposes, we reserve the right to suspend or remove access to the platform for customers or customers’ end users’ that we determine are not complying with the Messaging Policy, or who are not following the law in any applicable area or applicable communications industry guidelines or standards, in some instances with limited notice in the case of serious violations of this policy.
1. Ramp-Up Model:
Every new sub-account (from April 20, 2022) that are on PushPress Grow - Phone System going forward will follow the "Ramp Up Model".
The is multiplied each day by the number of days (till the 7th day) the location has spent with us. Starting the 8th day the location will have the limit set to 5000 SMS/day. Below is the table which will give you a detailed idea:
SMS limit
Day | Limit [SMS] |
1 | 250 |
2 | 500 |
3 | 750 |
4 | 1000 |
5 | 1250 |
6 | 1500 |
7 | 1750 |
8th Day & Ongoing | 5000 |
Please Note:
The daily counterresets every day at midnight 00:00:01 AM UTC. If the limit is reached before the rest time the account is locked for the rest of the time period.
Why the change?
PushPress Grow - Phone policy was implemented to:
Avoid SMS Spam blasts from fake signups. New sub-accounts on PushPress Grow - Phone will follow the Ramp-Up Model
Avoid getting sub-accounts blocked due to suspicious activity
Avoid legal actions due to increased spamming to non-consenting customers. Only bulk SMS sending will have daily limitations to avoid sub-account suspension due to non-compliant messaging activity.
What error screens or notifications will a sub-account see during a violation
Conversation Error: You have exceeded your SMS sending limit.
Bulk Action: You are allowed to send 5000 message(s) in a day. You have already sent 5000 message(s). If you wish to proceed, 1 Message(s) will be failed.
2. Spam Message Handling:
Each of the messages sent out from the sub-account ends up with the following 4 statuses:
Sent: The messages whose response we did not receive from the carrier, can be in any of the three statuses below.
Delivered: The messages which were successfully delivered and sent to the contact.
Failed: The messages which were canceled or were not sent to the carrier to forward to the contact.
Undelivered: The message sent was suspicious or did not fulfill the messaging policy.
As part of this feature, we will only consider Undelivered messages. All the undelivered messages end up with a particular error code and we will start storing them at each of the message levels. We will further use them to start enabling Temporary/Permanent DND at a contact level so that new SMSs are not sent to them increasing your deliverability rate.
The below table summarizes the undelivered SMS error codes and what each of them means and the relevant remediation measure we are taking:
Response Code | Code Description | Remediation |
30005 | User Inactive/Number does not exist | Enable Temporary DND |
30003 | Unreachable- Out of Service | Enable Temporary DND |
30004 | Do not want SMS/DND enabled | Enable Permanent DND |
30006 | Landline/Incapable to receive SMS | Enable Temporary DND |
30008 | None of the above scenarios matched | Do nothing |
Temporary DND: The DND set at a contact level can be revoked by the agency or location.
Permanent DND: The DND set at the contact level cannot be revoked by the agency or the location as the contact is incapable to receive the message or had opted out from receiving messages.
Opt-Out Keyword: Individuals must have the ability to revoke consent at any time by replying with a standard opt-out keyword like STOP, Unsubscribe, etc. In this case, also a permanent DND will be enabled at the contact level.
Advantage:
This will restrict the location from sending SMS to non-relevant contacts, eventually increasing the deliverability rate and decreasing the possibility of getting blocked.
The locations will only send out messages to the contacts who have opted in.
Spam messaging error screens:
Conversation: Cannot send messages as DND is active for SMS.
Bulk Action: All SMS sent via features like workflow, and bulk SMS will automatically skip the DND-marked contacts from the sender list.
How to revoke the DND for a contact?
For Temporary DND, go to the contact details and remove the DND flag, below is the screenshot of the sample screen:
For Permanent DND, you cannot revoke the same from UI. To revoke the permanent DND, request the contact to send a reply with the "START", "YES", and "UNSTOP" keywords to the number. This should automatically remove the DND from the contract.
Please Note:
If the START keyword does not revoke the DND and still incoming/outgoing messages are failing, please raise a support ticket.
3. Opt-Out Language addition
The consent for sending out communications cannot be bought and the only way is to take explicit consent from the user for the SMS campaigns and communications.
The consent is taken by a specific entity, in our case sub-accounts that are the actual sender of these communications.
To comply with the messaging policies each of the initial messages sent out by the company to an end-user should have below two mandatory information, ie, Sender ID and opt-out Language:
Opt-Out Language: The end user should have the capability to remove the consent at any time, so similar to above each initial message should also have opt-out keywords like STOP, UNSUBSCRIBE, etc. We will additionally add the opt-out language: “Reply STOP to unsubscribe".
Please note:
“Opt out message” feature is applicable toBulk action(Bulk SMS), Workflow and campaigns and is not applicable to One on One conversation unless it is the first text being sent out to a new contact and that contact has never sent a text to the LC phone number before.
Sample Opt-Out Language message screen:
How can I customize the opt-out message?
Go to Sub-account -> Settings -> Business Info -> General, where you can customize the opt-out message, below is the screenshot for reference:
What happens if my message already has an opt-out keyword?
In case the message already has one of the opt-out keywords mentioned in the above screenshot, no opt-out keyword will be added from our side.
What happens when an end-user replies with the STOP keyword?
If individuals reply with a standard opt-out keyword like STOP, the consent to send SMS will be revoked. All upcoming and queued messages will be failed. Also, a permanent DND will be enabled at the contact level.
Please Note:
This is mandatory info that should be shared with the end customer so this is a mandatory check for all the initial messages.
4. Sender Information addition
The consent for sending out communications cannot be bought and the only way is to take explicit consent from the user for the SMS campaigns and communications.
The consent is taken by a specific entity, in our case locations that are the actual sender of these communications.
To comply with the messaging policies each of the initial messages sent out by the company to an end-user should have below two mandatory information, ie, Sender ID and opt-out Language:
SenderID: Every message you send must clearly identify you (the party that obtained the opt-in from the recipient) as the sender, except in follow-up messages of an ongoing conversation. We will additionally add the sender info: “Thanks, <Location Name>".
Please note:
“Sender ID” feature is only applicable toBulk action(Bulk SMS), Workflow and campaignsand is not applicable to One on One conversation.
Sample message screen:
How can I customize the opt-out message?
Go to Sub-account -> Settings -> Business Info -> General, where you can customize the opt-out message, below is the screenshot for reference:
Please Note:
This is mandatory info that should be shared with the end customer so this is a mandatory check for all the initial messages.
5. Error and Opt-out Rate Monitoring
We are focused on helping our customers deliver trusted communications. To make sure that the carrier does not block or suspend the account permanently based on bad usage.
We will be monitoring the delivery rate of the overall account and be taking proactive measures(as mentioned below) to keep the delivery rate in check:
Violation Email ****We will send out an email notification as soon as the subaccount hits the error rate of 8% and opt-out rate of 1%.
Temporary Account Restriction - We will send out a suspension email as the subaccount hits the error rate of 12.5% and opt-out rate of 2.5%.
Please Note:
As soon as the account will hit the temporary suspension all upcoming outbound SMS will be failed till 00:00 AM UTC.
What should we do when we get a violation email?
Stop all your workflows, campaigns, triggers, and/or bulk actions to contacts who have not explicitly opted in to receive messages from the sub-account.
Enable and customize the Opt Out language and SenderID message as per your use case so that all the upcoming messages are not flagged.
Please discuss this with your client to make no bulk communication or messages blast or cold prospecting message campaigns are sent in the near future before we receive your reply to this ticket.
What are error and opt-out rates and good to have a threshold?
A High Opt-Out Rate indicates that contacts receiving your messages have objected, generated complaints, or marked your SMS as spam. A good opt-out rate is typically in the range of 0—1%. Once the opt-out rate hits 2%, the sub-account will be locked for sending text messages for 24 hours.
A High Delivery Error Rate indicates that you are sending SMS to contacts that are no longer in service, are unreachable, or use a non-SMS-capable device such as a landline. This may also mean that external carrier filters are refusing to deliver your SMS due to bad sending behavior in the past. A good error rate is typically in the range of 0—6%. Once the error rate hits 12%, the sub-account will be locked for sending text messages for 24 hours.
What do I do to get the subaccount suspension removed early?
The subaccount suspension will be lifted in 24 hours. However, if the sub-account is permanently suspended. Please refer to the article Why is your account suspended to unsuspend the sub-account.
Please Note:
One on One conversation, Test SMS, Resend Message, and MissedCallTextBack are allowed even if the account is suspended.
FAQs
How often does the SMS limit last?
The SMS limit will refresh every 24 hours. If the account is brand new then each day the increments will increase according to the table above. Once you have hit the 8th day your SMS limit will be capped at 5000 per day.
I'd like to send more than 5000 SMS per day, how can I increase my limit?
Once your location(s) hit the 8th-day mark (5000 SMS per day), you may reach out to support and request a Limit extension.
What happens when we hit our daily limit, will we be able to respond to SMS if a lead replies?
No, you cannot respond manually to incoming messages. SMS daily limits will affect all messaging activities including manual SMS in conversation, automation within workflows, and bulk actions.
Can we undo the DND option in bulk?
No, we cannot because this is to prevent sending SMS in bulk again after DND is enabled for the contacts.
Is the auto append Sender ID and Opt-Out Language feature applying to every first text of workflow or manual SMS as well?
This feature is only applicable to Bulk action (Bulk SMS) and is not applicable to One on One conversation or Workflows or Campaigns