*** UPDATE on 10/1/21 ***
Due to pressure placed on TMobile by non-profits and political organizations ahead of the 2021 election, they have postponed the Oct. 1 deadline for both the $50 fee per campaign and filtering or blocking of non-registered traffic. There is no new deadline at this time. Despite this, it is still advised that you begin the registration process when you can. Update via Twilio.
In addition, according to the Campaign Registry, the deadline for Brands with active campaigns to obtain the “Verified” status has been extended to 11/01/2021. All campaigns for unverified Brands will be deactivated after that date.
Let’s start with the most obvious thing you should do before the 10DLC October 1, 2021 deadline: register with The Campaign Registry! If your mobile platform vendor hasn’t prompted you to do so yet, make sure you reach out to get this process rolling before October 1. I’ve already received messages from ThruText, Hustle, SignalWire, Twilio, Scale to Win, and Politics Rewired reminding me to register. If your vendor isn’t planning on complying with 10DLC requirements, I strongly suggest you switch vendors.
This deadline is primarily related to TMobile beginning to impose fees and fines. Mobile campaigns that have been registered and already provisioned on the TMobile network before October 1 will not be charged the one-time $50 fee. All future campaigns registered after that date will need to pay the $50 one-time fee per campaign. If you still haven’t submitted your 10DLC brand registration details by September 27 your organization may not be able to send messages starting October 1 and need to wait until up to 5 business days after they have provided their registration info.
Some vendors have connected to The Campaign Registry (TCR) via their API, and you can simply go through them, others will advise and help you go directly through The Campaign Registry Portal. You will have to go through several steps to register
STEP #1 – BRAND REGISTRATION
This is the registration of your organization or political campaign. For instance, your brand name would be “The Nonprofit of America” or “John Doe Committee for Senate.” Please be sure to have the necessary information available, including your organization’s LEGAL NAME, Employer Identification Number (EIN), phone number, email, and official street address. Additionally, you will be asked to verify whether your organization is a nonprofit or political entity. If any of this information doesn’t match your organization’s filings the registration will be rejected and the appeal process will significantly delay your messaging. So please verify all the information is accurate before submitting it. Newly registered non-profit Brands that fail a 501-c check will be eligible for the “verified” status and have all Standard Use Cases available, but not special use cases.
STEP #2 – USE CASE REGISTRATION
You will be asked to select one to five use cases that most likely apply to non-profit, political, and government entities. Each has its own costs & message volume and throughput limits. Learn more here:
Special Use Cases (all not included):
- Charities: Communications from a registered Charity / 501(c)(3) Nonprofit aimed at providing help and raising money for those in need. There are no additional network access fees applied by the carriers for this use case. Limited to 501(c)(3) nonprofits.
- Emergency Services: Notification services designed to support public safety/health during natural disasters, armed conflicts, pandemics, and other national or regional emergencies. 501c3 nonprofit organizations and quasi-government entities are also allowed to apply for the “Emergency Services” use case.
- Political: 501c4 organizations, associations (501c5) and unions/labor (501c6). Part of an organized effort to influence the decision-making of a specific group.
- Political with Campaign Verify (CV) Token: Federal, state, and local campaigns, political parties, and PACS. You must wait to be vetted by Campaign Verify to submit your use case with an assigned CV Token. Active “Political” Use Case campaigns will be deactivated upon Campaign Verify token expiration. 527s will soon be under this category as well and require CV vetting.
- Social: This is defined as communications between public figures/celebrities and their communities. So this could be applied to elected officials messaging their constituents, or possibly their campaigns messaging voters. The other catch is that external vetting through Aegis or WMC Global is required and likely requires a hefty fee.
Standard Use Cases (all not included):
- Higher Education: Messaging on behalf of colleges or universities
- New “K-12 Education” Use Case will be supported for all Carriers beginning 10/7/21.
- Mixed Messaging: Any mobile brand that has 2-5 use cases.
- Marketing: content and brand promotion
STEP #3 – CAMPAIGN VERIFY (ONLY FOR POLITICAL ENTITIES)
For federal, state, and municipal political campaigns, parties, 527s, and PACs there is an additional step to getting your brand messaging vetted. These entities must register with Campaign Verify to receive their Campaign Verify Token. Begin this process before or while you are beginning to register your brand. I’ve heard predictions that this process could add 5-10 days to the verification process and it is strongly encouraged to get started as soon as possible.
Additionally, there is a fee for verification, payable to Campaign Verify (currently $95 brand). Once you’ve received your Campaign Verify Token you can enter it on the Brand & Use Case Registration page when you are registering with TCR or with your mobile vendor (CSP). Campaign Verify accepts email as a verification method for all campaigns as long as a matching email address is in the campaign filing record; if not, the PIN will be mailed via USPS to the postal address listed, assuming it matches the postal address in the filing record.
Only one Campaign Verify token will be allowed per Brand. Importing a new CV token will replace the existing one (implementation on 10/7/21). All Campaign Verify tokens received in 2021 will be valid until January 31, 2023. So all 2022 campaigns can start registering now.
STEP #4 – Register Your Campaign and the 10DLC #s associated with it
Every messaging outreach is considered a different campaign. So if you are doing “Early Vote and Mail Ballot” messaging – that’s one campaign and a text about a rally or Fundraising event for your candidate is another campaign. You need to submit approval for each to get started.
If you are planning to target a large universe and likely sending 200k SMS or more per day, using 50+ local numbers you’ll also need to submit approval for a Special Business Review (SBR) with TMobile. This will further add time and cost to the process.
STEP #5 – WAIT TO BE APPROVED TO BEGIN TEXTING
The verification and approval process can take between 5 days or several weeks depending on if there is a need to appeal or if there are issues with your registration submission for either TCR or Campaign Verify. So you need to take this into account. If you are planning for instance to start your GOTV texting during October, depending on when you submit your registration you may not be able to text until mid-October or right before Election Day.
FEES & FINES
Next here is a quick reminder of what fees and fines will apply for 10DLC and if you don’t register for 10DLC.
Fees for 10DLC using A2P Channels:
- Brand Registration Fee ($4 one-time)
- Campaign Registration Fee (monthly per campaign)
- Regular/Political: $10/month for the duration of the campaign
- Charity: $5/month for the duration of the campaign
- Low Throughput: $2/month for the duration of the campaign
- TMobile Campaign Fee ($50/campaign)
- Message Cap Increase to over 200k SMS per day ($5,000/campaign)
- 50+ 10DLC #s ($5,000/campaign)
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.
Fees & Fines if using 10DLC Unregistered:
First of all, there will be higher per-message fees associated with unregistered campaign texts that are sent. For instance, AT&T and TMobile will 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 per message rate. 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. Check out the 10DLC FAQ
In addition, these penalties will apply if you get caught not following their rules:
- Text Enablement ($10,000 pass-through fee): Imposed if T-Mobile receives a complaint where messages have been sent prior to verification of message sender ownership and/or letter of authorization.
- Grey Route ($10 fee per message): Imposed if A2P messages are found being sent over P2P routes.
- 10DLC Long Code Messaging Program Evasion ($1,000 pass-through fee): Imposed if a program is found to be using evasive techniques such as snowshoeing, dynamic routing, or unauthorized number replacement.
- Content Violation ($10,000 pass-through fee): Imposed (each instance) for 3+ notifications of content that is found to be violating the T-Mobile Code of Conduct. This includes SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco) violations, spam, phishing, and messaging that meets the Severity 0 violation threshold per the CTIA Short Code Monitoring Handbook.
For more details on 10DLC I suggest you read: