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A2P Compliance - 10DLC and Toll-Free

U.S. A2P Customer Obligations

Aerialink is committed to creating a healthy messaging ecosystem that serves all participants and to keeping our customers informed about recent changes in the industry, including the CTIA Messaging Principles and Best Practices.

All customers sending A2P traffic are subject to the guidelines for A2P traffic set by the CTIA.

The number types that deliver messages over an A2P service include:
short codes
toll-free numbers (800, 833, 844, 855,866, 877, 888)
standard 10 digit numbers on the following schedule:

  • Verizon MMS A2P service rolled out Jan 14, 2020
  • Verizon SMS A2P service effective Feb 1, 2020
  • Other carriers A2P service – TBA

Note that any and all participating carriers may include their own, additional rules and regulations for what constitutes A2P messaging above and beyond the definitions found in the CTIA Best Practices Guidelines. We recommend that you check these pages regularly for updates as the telecommunications ecosystem continues to evolve. As such, the information below may be updated or changed without notice.

The following guidelines should be maintained by all Aerialink customers for compliant A2P messaging. In addition to our Acceptable Use Policy, Aerialink customers using A2P messaging routes:

  1. Must obtain express consent prior to sending messages to any recipients.
  2. Must provide an opt-out method, permitting end-users to decline to receive any further messages.
  3. Must not send messages violating CTIA or carrier rules or regulations for acceptable A2P messaging. Note that these rules and regulations are subject to change. Those changes will be reflected in the Aerialink Acceptable Use Policy.
  4. Understand that carriers reserve the right to re-evaluate messaging use-cases at any time and may shut down existing messaging programs at their discretion.
  5. Must, if intending to resell A2P services, assume responsibility for the maintenance of compliant rules and regulations equal to or greater than those imposed by the CTIA, carriers and Aerialink.
  6. Must, if intending to resell A2P services, obtain use-case information from all clients and maintain the right to audit said programs. Aerialink customers must be able to provide this information to Aerialink upon request.
  7. Must not use A2P messaging services to send Protected Health Information.
  8. Must provide appropriate security and privacy controls to protect subscribers and maintain opt-in and opt-out integrity and full confidentiality of end-user information.
  9. Must provide terms of service and privacy policy.

Disallowed Provider Behavior

The following traits are considered by the carriers to be suspicious and indicative of spam or fraudulent traffic. As such, campaigns found to be doing the following are not complying with best practices guidelines:

  1. Snowshoeing - utilizing a large block of numbers to spread high-velocity traffic among them to avoid carrier spam filters.
  2. Ignoring or Avoiding Opt-Outs - any attempts to make it difficult for an end-user to opt out run the risk of noncompliance with the FCC TCPA, as are instances of ignoring opt-out attempts made in a reasonable manner.
  3. URL Cycling, Redirects and Forwarding - campaigns utilizing strange or misleading URL behavior to manipulate end-user consent, attention or capture information.
  4. Number Cycling - dropping blocks of numbers which have been burned by the carriers and replacing with fresh numbers to simply repeat the process.

Deliverability Best-Practices

The following recommendations help ensure compliance with CTIA and carrier guidelines, as well as maintain best deliverability with lowest risk of incurring carrier blocks.

  1. Use as few numbers for your campaign as possible. While there are some use-cases which require the use of multiple numbers (e.g. your company has different departments and you want a different TFN for each), limit the use of one number per clear use-case (e.g. one number per department rather than two). This helps to allay carrier concerns of snowshoeing.
  2. Keep branding, URL domains and messaging consistent. Multiple names, differing or changing URLs and mis-matched content cause confusion and concern.
  3. Keep phrasing conversational. Messages that sound like the transcribed words of a carnival barker will always appear spammy, even if they are legitimate.
  4. Obtain consent directly. Consent should be obtained directly from the end-user to receive the text messages you intend to send.
  5. Maintain expected frequency. If your advertising told end-users they would receive messages once a month, hold to that. If your advertising doesn’t indicate frequency at all, it might be time to add it.

Aerialink Compliance articles are for informational use only. They do not constitute, and should not be taken as or in place of, legal advice. Aerialink customers are responsible for meeting all legal requirements applicable to their programs and are strongly encouraged to consult formal legal counsel.