As many of you have already heard there are some major changes happening in the texting industry, with carriers implementing and enforcing new rules and requirements for organizational texting from a local phone #, also known as long code or 10DLC (10-digit Longcode).
This article is a follow-up to 10DLC Could Signal the End of P2P Texting which was written in mid-February. Since that was published, I have had multiple new and follow-up conversations with texting providers and aggregators or CSPs (ie. cloud service providers) about these new rules, and how they will impact nonprofit and political organizations.
I’ve put together some frequently asked questions I’ve received in the last few weeks to help progressive organizations understand these changes.
No, within our industry we define peer-to-peer texting (P2P) by the type of technology used to send text messages. More specifically, whether a platform or software automatically sends the texts, or whether that platform requires a person to press send on each text message being sent out. This is what separates P2P from Broadcast text messaging which allows a person to use a platform to send one message out to hundreds, thousands, or even millions at once using what the FCC defines as an autodialer.
The carriers instead define P2P primarily based on the sender. They view all peer-to-peer texts as being on the “consumer” side meaning, one individual using a handset (ie. mobile device) to text another individual. If an organization is sending the text messages they now immediately define the messages as A2P, or application-to-person. Broadcast texting is also A2P texting.
3.3.1 Consumer (P2P) A Consumer is an individual person who subscribes to specific wireless messaging services or messaging applications. Consumers do not include agents of businesses, organizations, or entities that send messages to Consumers.
- Volume is typically less than 1,000 messages sent or received daily.
- Throughput 15-60 messages sent per minute.
- One phone # assigned to a single consumer.
- Less than 100 unique recipients (10 is the average).
- No more than 35 repetitive messages.
So basically, all organizational texting is now defined as A2P.
Application-to-Person (A2P) texting is when an organization uses a platform or software to text individuals (or consumers) who have consented to receive text messages. Based on the CTIA definition, any mass texting from an organization or entity, even if one-on-one from an “agent,” without an auto-dialer, is considered “Non-Consumer (A2P).”
3.3.2 Non-Consumer (A2P) A Non-Consumer is a business, organization, or entity that uses messaging to communicate with Consumers. Examples may include but are not limited to, large-to-small businesses, financial institutions, schools, medical practices, customer service entities, non-profit organizations, and political campaigns.
Texting from any type of number (local, toll-free, or shortcode) from an organization is now considered A2P. Carriers have different channels for P2P consumer and A2P non-consumer texting traffic.
The 10DLC program is being rolled out in 2021 by mobile carriers, like AT&T and TMobile, as a way to prevent spam or “unwanted messaging” and will make it easier to hold senders accountable.
10DLC is short for 10-Digit Long Code, and it is basically a local phone number being used for A2P texting. This rollout has been expected for 3+ years. Originally 10DLC was thought to be a separate message delivery product being offered by the carriers with higher throughput (# of messages per minute) for broadcast (A2P) texting. Long codes were not previously provisioned for broadcast or blast texting, so you needed to use toll-free numbers or short codes. We thought that regular local number texting with lower throughput would remain for one-on-one (P2P) texting. But now it appears all long code (ie. local phone number) usage by organizations is being lumped into the category of 10DLC A2P texting.
The CTIA, the industry association and regulatory body for the mobile carriers (AT&T, Verizon, TMobile, et al) is signaling that all private entities, which includes campaigns and nonprofit organizations need to register their “brand” and each texting campaign if they plan on texting using a long code (10DLC).
It depends. If you are planning to continue sending text messages from a local phone number (ie. 10DLC) then YES, you must register your organization and each individual texting outreach campaign with the campaign registry. If you are planning to switch to toll-free or shortcode, you don’t need to register with the “Campaign Registry” but you do need to follow separate registration processes for those types of numbers.
Your texting platform or aggregator/cloud service provider (ie. Twilio, Signal Wire, Bandwidth, YTel, Telnyx, et al.) will be able to guide you through the process of registering your organization/brand and then registering your campaign which will be associated with the 10DLC you will be using. You can start registering on April 1, 2021.
One of the requirements to register is to show proof that you are collecting opt-ins and texting a list of individuals who have consented to receive text messages from your organization.
Once your brand and campaign(s) are registered you will be assigned a “Trust Score” which will determine how many messages your campaign and 10DLC numbers can send per minute or per day (ie. throughput speed).
A “Trust Score” is a ranking assigned to your campaign based on past texting history with your brand, type of organization, and the type of messages you are planning to send. It is based on a set of algorithms built by the carriers that are completely unknown. There is already a lot of concern from groups over the lack of transparency associated with this score and how it is determined.
Once you receive a score it can be appealed, but you must use a select list of vendors to conduct an audit to reassess your “Trust Score” and this can cost around $5,000.
A low “Trust Score” (0-65) means your texting campaign is considered “High Risk” and your messaging throughput, or send speed can be limited to 1 - 0.2 messages per second (mps) by AT&T and TMobile won’t let you send more than 2,000-10,000 messages per day.
A high “Trust Score” (76-100) means your texting campaign is considered “Low Risk” and your messaging throughput, or send speed can be up to 60 messages per second (mps) by AT&T and TMobile caps your message output per day at 200,000.
So while much better than a low trust score, if you previously ran peer-to-peer campaigns via a set of local numbers that sent hundreds of thousands, or millions of messages daily this is going to definitely put a halt to that.
If you decide not to register your organization or campaign during the “pre-registration” period between April 1 and June 1, 2021, and continue to send text messages from a local number there will be penalty fees charged by TMobile and AT&T. First of all there will be higher per-message fees associated with unregistered campaign texts that are sent. For instance, AT&T plans to tack on an additional $0.004 per message, which seems low unless it’s multiplied by half a million messages ($2,000). And that is on top of the regular messaging costs. TMobile is playing hardball though and planning to fine $10 for each message segment (160 character SMS) sent by an unregistered campaign, which would be a $10,000 fine for sending only 10k SMS.
That’s just the monetary piece. There is also a 90% chance your messages will be blocked by the carriers when their algorithm notices the number you are texting from isn’t registered with a campaign or brand. So most likely your messages won’t even get delivered.
There are additional fees associated with registering, but they are lower than if you don’t register. First of all, you must pay a one-time brand registration fee of $4. Then you must pay a monthly fee for each campaign you have registered:
- Regular Campaign: $10/mo
- Mixed-Use (low volume): $2/mo
- Charity (501c3): $5/mo
The per-message segment cost will have a $0.002 - $0.003 fee tacked on. So if you are paying 1 cent per SMS, you’ll be paying around 1.2 cents per 160 character segment. The fees are higher when it comes to MMS.
So you probably noticed I only mentioned AT&T and TMobile 10DLC fees. That is because they launched both of their 10DLC programs in coordination between March and May of 2021.
Verizon released their 10DLC program in January 2020 to little fanfare, since the other large carriers weren’t on board yet. Plus, their release was similar to what those of us in the texting space expected, which was simply a local # option for broadcast texting. We didn’t see this as interfering in any way with what our industry refers to as peer-to-peer texting (ie. Hustle, Spoke, ThruText, etc.).
As far as I know, they also aren’t tacking on any additional fees, but given what their counterparts are doing that could change, and they might align with the other carriers. We’ll keep you posted if their policies change.
The short answer is no. All A2P texting requires an opt-in. If you were already running a broadcast texting program, then you are probably familiar with the required opt-in disclaimer language the carriers require. Now one-on-one texting from a P2P Platform (ie. Spoke, Hustle, ThruText, et al) is considered A2P and therefore held to those same opt-in requirements.
You can only text an individual if you have received their consent to send text messages from your organization or campaign. You can no longer just buy a list and text it. So cold texting a targeted voter file to remind them to vote is not something we can do as of June 2021. So yes, this is going to greatly impact campaign work around 2021 and 2022 elections. It will also impact polling and consulting firms that began to rely on P2P texting platforms to poll targeted demographics.
The long answer is slightly more complicated but doesn’t really change things unless the carriers begin to waver on some of these new policies. If you want the long answer we can set up a call.
Yes, there was a court case this past summer that determined that the P2P texting platforms our industry uses are not considered autodialers and therefore not held to the TCPA opt-in requirements. So if you try to text a list of numbers without an opt-in you won’t get sued and fined based on a TCPA violation. But that doesn’t change what the carriers are doing.
The carriers have found a way through their 10DLC rollout to prevent organizations from using P2P Platforms to send texts via a local number via “Consumer P2P” channels. Part of that includes requiring an opt-in.
Many of you are probably thinking well if I have their cell phone number because they donated or filled out a petition they must have opted in right? Unfortunately no, there is specific opt-in disclaimer language that must be followed on all forms or entry points.
The CTIA Messaging Principles and Best Practices dictate the opt-in requirements (see section 5). Now is the time to build an opt-in program. If you were using a peer-to-peer texting tool to message your supporters, donors and/or volunteers, by collecting opt-ins you can transition to a broadcast texting program and save time and money (toll-free or shortcode).
If you are wondering how do I even start collecting opt-ins from my supporters, let’s set up a call.
It should not impact your broadcast texting program as long as you are using a toll-free number (ie. 1800) or shortcode (ie. 66539). If you were incorrectly using a regular long code (ie. local number) you will need to register with the Campaign Registry as noted above.
The only major change that went into effect in 2020 is the elimination of shared shortcodes. This is when multiple organizations were texting from the same shortcode. If one bad actor was caught breaking the rules it could impact every organization on that shortcode.
If you are currently on a shared shortcode you will need to transition this year to your own dedicated shortcode, a toll-free number, or 10DLC.
There are going to continue to be new developments on this as 10DLC is rolled out and enforced. There are also progressive groups mobilizing to push back on these restrictions that would greatly impact civic engagement outreach work that could not have been successful without the ability to reach cold audiences without an opt-in. You can sign on to the Movement Cooperative's letter here.
If you have any questions about 10DLC or your own texting program please reach out. We are here to help organizations and campaigns think strategically about their texting outreach, remain compliant, and build strong mobile programs that emphasize engagement and impact.