Changes to Business Texting with the Introduction of 10DLC Policies

 

Due to changes over the last few years in how business texting is classified by the Federal Communications Commission (FCC) and handled by wireless carriers (AT&T, Verizon, T-Mobile, etc.), some carriers are beginning to implement new policies and fees for businesses that offer or use business texting services

As your trusted industry partner who is navigating these changes and their impact on HawkSoft Text Messaging, we want to help agencies understand how the changes made by wireless carriers may affect them. 

Please be aware that these new policies are still an area of volatility in the market, and many carriers have not yet finalized or are rapidly changing their policies. This article is meant to give an overview of how HawkSoft understands the situation at the time of this writing. Policies discussed here are explained to the best of our knowledge and may be subject to change. We will attempt to keep this article updated for the foreseeable future. Updates will be clearly marked with a date at the top of this article.

 

In this article:

 

What is A2P messaging?

A2P stands for application-to-person, meaning a business that uses an application to send text messages to a consumer (business texting). Wireless carriers classify A2P messaging differently from P2P texting (person-to-person texting like you use with your friends and family), due to the high volume of texts being sent. A2P texts must be sent through special channels or routes that can handle higher throughput levels (a higher number of texts sent per minute).

 

What is 10DLC?

10DLC stands for 10-digit long code, which is a traditional 10-digit phone number that has a local area code. 10DLC is a messaging channel with throughput levels suitable for text message campaigns by businesses, and is sanctioned by wireless carriers for A2P messaging. 

While 10-digit numbers were originally created for person-to-person (P2P) landline use, many businesses now use them for A2P texting instead of toll-free numbers or short codes (abbreviated 5 or 6 digit numbers designed to send large volumes of text messages). This has caused wireless carriers to create specific 10DLC routes for business texting with higher throughput caps. 

When we talk about 10DLC here, we’re not referring to all 10-digit phone numbers. We’re referring to routes that wireless carriers use specifically for business texting from local numbers (the method of sending the message, rather than the phone number itself). 


What are the changes to business texting on 10DLC?

In December 2018, the Federal Communications Commission (FCC) declared text messaging an information service. This classifies text messaging differently from phone calls and allows wireless carriers to set their own rules, pricing, and policies for A2P messaging without being subjected to the same regulations that apply to telecommunications. Additionally, in 2019 the Cellular Telecommunications Industry Association (CTIA), a trade association of phone service providers, officially designated short codes, toll-free numbers, and 10DLC routes as A2P messaging traffic. 

Following these rulings on business texting, wireless carriers began creating their own policies for A2P messages sent on 10DLC routes. Regulating 10DLC traffic allows wireless carriers to better protect consumers from spam, telemarketing, and unwanted messages by requiring brands (e.g. independent agencies) to declare the nature of the text campaigns they intend to send and inflicting penalties for non-compliance. Regulation also provides some benefits to businesses, such as a higher throughput for business texting (more messages sent per minute) and more reliable deliverability. 

However, this self-regulation also allows each carrier the freedom to charge fees to businesses as they see fit. Because businesses have customers across multiple wireless carriers, they’re forced to comply with and be held accountable to the 10DLC policies, usage-based fees, and penalties for each wireless carrier. These fees and penalties can stack up and can become costly.

Some wireless carriers are already enforcing some policies and higher usage-based fees for 10DLC routes, with others expected to be implemented later in 2021.


Some wireless carriers are already enforcing some policies and higher usage-based fees for 10DLC routes, with others expected to be implemented later in 2021. Businesses like HawkSoft that provide text messaging services to independent agencies are scrambling to understand how each carrier’s program and fees work, how to comply with their policies, and when compliance is required for the entities sending texts (independent agencies).

 

What do wireless carrier 10DLC policies include? 

While every wireless carrier’s 10DLC program is different, most include one, some, or all of the following elements: 

  • Per-message surcharges
  • Brand and campaign registration
  • Registration fees
  • Non-compliance fines and penalties

 

Per-message surcharges

Wireless carriers are starting to charge additional per-message fees for incoming and outgoing 10DLC messages from business texting platforms (like HawkSoft Text Messaging). While most carriers previously charged per-message surcharges for A2P texting, the fees are now higher in order to provide for the higher throughput needed for 10DLC routes. Many wireless carriers are already enforcing these higher per-message surcharges today, including Verizon, AT&T, T-Mobile/Sprint, and US Cellular.

 

Brand and campaign registration

The biggest change happening with 10DLC programs is that some wireless carriers are requiring more information about each brand (agency) and campaign (type of message they send), such as the industry they’re in, the name of the business, and how opt-ins and opt-outs will be handled. This identifies the business sending text messages and protects consumers from spam and unwanted messages. 

Entities in Business Texting

AT&T and T-Mobile are requiring brands (i.e., your agency) to register your company and your campaigns with The Campaign Registry (TCR), a sanctioned third party that works with carriers, messaging companies, and industry partners to establish common standards for 10DLC messaging. The texting platform (e.g. HawkSoft) will coordinate registration of brands and campaigns for the businesses using their platforms. Independent agencies will need to register a campaign type. Here is the type of information TCR requires for brand and campaign registration (subject to change by TCR).

 

Brand (agency) registration information

  • Legal Company Name*
  • DBA or Brand Name (if different from legal name)
  • Country of Registration*
  • What type of legal form is the organization?*
  • Tax Number/ID/EIN*
  • Address*
  • Website*
  • Stock Symbol* (if a publicly traded company) 
  • Stock Exchange
  • Vertical Type*
    • Will be Insurance for independent agencies
  • Contact Information: Email*
  • Contact Information: Phone*

 

Campaign registration information

  • Associated Brand*
  • Use Case* 
    • Choose from list of options (may differ depending on agency)
  • Vertical*
    • Will be Insurance for independent agencies   
  • Campaign Description*
  • Sample Message(s)*
  • Campaign and Content Attributes (all Y/N questions)*
    • Subscriber Opt-In: Are you collecting and processing consumer opt-in?
    • Subscriber Opt-Out: Are you collecting and processing consumer opt-out?
    • Subscriber Help: Have you implemented a response to the HELP keyword informing customers of how they can contact the message sender?
    • Number Pooling: Will more than 50 TNs be used for this campaign?
    • Direct Lending or Loan Arrangement: Will the campaign include content related to direct lending or other loan arrangements?
    • Embedded Link: Are you using an embedded link of any kind?
    • Embedded Phone Number: Are you using any embedded phone number beyond the contact number in the HELP response?
    • Affiliate Marketing: Is affiliate marketing being used (or was used in the creation of the campaign)?
    • Age-Gated Content: Will the campaign include any age-gated content as defined by carrier and CTIA guidelines?

*Required information

 

Registration fees

TCR will also charge fees to texting platforms for each brand (agency) and campaign they have registered. In addition, wireless carriers may charge their own campaign registration fees on top of TCR fees. While wireless carriers have not yet finalized their campaign registration fees, they may begin charging fees for registration as soon as July. Here’s the information we have so far on the types of registration fees the TCR and wireless carriers plan to charge (these are subject to change by TCR and wireless carriers).

 

Fee Type

Frequency

Charged per

Charged by

Brand registration fee One time (upon brand registration) Brand TCR
Carrier campaign registration fee One time (upon campaign registration) Campaign T-Mobile
Monthly campaign fee Monthly Campaign TCR

 

 

Non-compliance fines and penalties

Wireless carriers may also impose penalties and fines if texting platforms and the businesses using them do not comply with their 10DLC policies. Most commonly, wireless carriers can block or refuse to send text messages that do not comply with their policies. In addition, they may fine the texting platform (e.g. HawkSoft) if any of their brands (agencies) and associated campaigns are not complying with policies. HawkSoft will have to pass these fees on to the non-compliant agency. All legal and financial liabilities as a result of non-compliance will rest on your agency. 

 

How might 10DLC policies affect agencies in the future? 

While wireless carriers are enforcing their 10DLC policies most directly on business texting platforms, this will have ramifications for the agencies that use these platforms. Here are some impacts agencies may see in the near future. HawkSoft, like other texting platforms, is considering each of these courses of action in order to comply with 10DLC policies and fees.

  • Additional information will be required for brand and campaign registration
  • Rates for business texting may increase
  • Business texting platforms may transition to using toll-free numbers
  • Opt-in and opt-out processes may be enforced instead of recommended



Additional information will be required for brand and campaign registration

Because business texting platforms are required to register every brand (agency) and their associated campaigns with TCR, they will need to collect the required information from each agency. Texting platforms will likely provide online forms to agencies that will pass the collected information to TCR. Because the texting platform will be held liable for any agencies who are not in compliance, platforms may disable texting services for agencies who do not provide the needed brand and campaign registration information.

 

Rates for business texting may increase

Because business texting platforms will be charged new per-message surcharges, campaign registration fees, and non-compliance fines by carriers, they may increase their rates for texting services in order to cover the higher costs.

 

Business texting platforms may transition to using toll-free numbers

Toll-free phone numbers are not subject to the same 10DLC regulations as local 10-digit phone numbers on 10DLC routes at this time. Therefore, business texting platforms may elect to transition agencies onto toll-free numbers instead of dealing with the additional regulations, fees, and liability for 10DLC. This would change the number that the agency texts from. However, it is possible that carriers may begin to implement policies and fees for toll-free numbers as well in the future, as they have for 10DLC. 

 

Opt-in and opt-out processes may be enforced instead of recommended

Opt-in is required from a customer before a business (including an agency) can legally text them. Learn more about the types of consent required for messaging in our blog on TCPA best practices. Currently, business texting platforms may leave it to the agency to manage the opt-in process. With more strict 10DLC policies in place from wireless carriers, including heavy fines for non-compliance, texting platforms may now require agencies to send an opt-in message to a customer before texting them. Alternatively, platforms may allow agencies to continue to collect opt-ins outside the platform but require them to provide proof of opt-in.

 

Keeping current on 10DLC

We hope this information helps your agency understand upcoming changes you may see from the business texting platform you use, whether it’s requests for additional information, higher rates in order to cover additional fees from wireless carriers, or stricter requirements for opt-in processes. As a technology partner for your agency, HawkSoft wants you to understand where these changes are coming from and how they may affect your agency. We assure you we are working with our texting provider to understand these changes, as well as the rapidly shifting information from wireless carriers, to come up with processes to keep our service and your agency in compliance. 

 

 

 

Learn about best practices for business texting

   TCPA Compliance & Best Practices   

 

 

 

 

Rachel Stauffer

Author: Rachel Stauffer

Rachel is the Content Manager at HawkSoft, where she focuses on creating engaging content for the independent agent community.

texting, text messaging, CTIA, texting regulations, agency management system texting, industry topics, 10DLC, A2P, TCR