Why texting customers from a business number got hard.

The short version

Below: how each gate works, the registry's own fees, the FCC's text rules as they read today, the Canadian rules, and where small businesses most often get caught, which is automatic text-back after a missed call.

Why the carriers, not a regulator, decide

Everything follows from the legal status of a text message. The FCC ruled in 2018 that SMS and MMS are not a common-carrier service: "Texting (SMS and MMS) is not a common-carrier service," as the Commission restated in its first robotext order in 2023.3 A phone company has to carry your voice call. It has no equivalent duty to deliver your text.

So the rules come from the carriers themselves, and the shared statement of those rules is CTIA's Messaging Principles and Best Practices. CTIA's own page still points to the May 2023 edition as "the current version".2 The document calls itself "a set of voluntary best practices developed by CTIA's member companies" and says they "do not impose, prescribe, or require contractual or technical implementation on messaging ecosystem stakeholders".1 In practice, though, the same document says that "All Service Providers may filter or block Unwanted Messages before they reach Consumers" and that a provider "may suspend the exchange of messaging traffic with or disconnect another Service Provider" to stop unwanted traffic.1 It also says stakeholders "may choose to implement modified and additional requirements through their individual guidelines, policies, and contracts."1 Our view: that sentence is how a voluntary document becomes binding on you. The carriers write the rules into their contracts with the platforms, and the platforms write them into yours.

You are a "Non-Consumer", even texting from your own phone

The principles sort messages into Consumer and Non-Consumer traffic (formerly P2P and A2P). A Non-Consumer is "a business, organization, or entity that uses messaging to communicate with Consumers", explicitly including "large-to-small businesses" and medical practices, and it "also include[s] agents, representatives, or any other individuals acting on behalf of Non-Consumers".1 An employee texting a customer about a job is Non-Consumer traffic, whatever handset they use.

The document also describes what normal personal texting looks like, as illustrative but not decisive thresholds:1

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The detail that matters most for small businesses is about automation. A person's auto-reply ("Driving now, can't talk") is still Consumer operation, but "automation in whole or in part used by a Non-Consumer to facilitate messaging is not typical Consumer operation."1 An automatic text-back from a business is business messaging, even if it sends ten messages a week.

Three lanes for business texts in the US

A business that wants to text people in the United States has three kinds of sender to choose from. They differ in who approves you, what it costs and how much you can send.

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A fourth option, texting from staff mobiles, is not a lane at all under the principles above: it is Non-Consumer traffic on a consumer plan, and nothing registers it.

A2P 10DLC and The Campaign Registry

10DLC stands for 10-digit long code, the ordinary North American number. The Campaign Registry (TCR) describes the arrangement plainly: US mobile network operators "are moving away from unsanctioned long codes and have launched 10DLC as a sanctioned A2P messaging service", and they ask the messaging platforms "to declare who is sending messages and what messaging is being sent."4

In TCR's vocabulary the Brand is your business, the CSP (Campaign Service Provider) is the platform that registers you, connectivity partners and DCAs (direct connect aggregators) carry traffic to the carriers, and the MNO is the carrier.4 Three facts from TCR's own material tend to surprise people:

• Every business that texts on 10DLC must register, not only marketers. "This includes businesses that do mass texting or marketing, as well as businesses that send individual messages, even if it is not for marketing purposes. All business messaging is considered non-consumer (A2P) messaging."4
• You cannot register yourself. "Currently, direct registration with TCR is not available for Brands"; a business works through a registered platform.5
• TCR does not approve anything. "The Campaign Registry (TCR) does not review, approve, or reject campaigns. This is solely done by the CSPs and their upstream connection partners. Typically, the more partners there are in the connection chain, the longer the campaign approval time."5 TCR also says it "is not a compliance house" and cannot advise on opt-ins or opt-outs.4

Brand registration and identity

A brand is registered with its tax identifier, and the name has to match. TCR asks for the EIN of a US brand (sole proprietors excepted) and says "It is crucial that the EIN/Tax ID matches the legal company name of the Brand you are registering for it to be correctly verified." A Canadian business can register with the first nine digits of its CRA Business Number, its corporation number or its registry ID, with the legal name and address as registered with Corporations Canada.5

Since 17 October 2024, publicly traded brands must also pass Authentication+, an email two-factor check of a named brand representative, before they can create campaigns; TCR said it would start with public companies and extend it later.7

Campaigns, vetting and throughput

A campaign is "the use case of your messaging", such as Marketing or Customer Care.4 Registration asks how end users opt in, opt out and get help, with a description of the messages.10 Standard use cases do not need carrier approval before or after registration; "Special" use cases may need vetting or carrier approval first.5

How much you can send depends on the brand and the campaign, not on how many numbers you put on it: "Throughput is determined based on who is sending the message (the Brand) and what is being sent (the Campaign), not on the amount of numbers associated with the Campaign. The best course of action to provide your client with higher throughput is to have them vetted."5 Third-party vetting, sold through TCR, "Produces a score (0-100)".6 This is the "trust score" platforms talk about.

The limits are set per carrier. One platform's documentation puts daily caps toward T-Mobile at 1,000 messages for a sole-proprietor brand, up to 2,000 for a low-volume standard brand, and from 2,000 up to unlimited for a standard brand "depending on your Trust Score".10

What it costs, from the published schedules

TCR publishes its fee guide (last updated 13 August 2026), and these are the charges it makes to platforms.6 Most platforms pass them on; some add their own fee on top.

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Platforms repackage these. Twilio, for example, lists a $4.50 sole-proprietor brand (TCR's guide says $4.00), a $4.50 low-volume standard brand, a $46 standard brand including secondary vetting, a $15 campaign vetting fee, and monthly campaign fees of $2, $10 and $1.50 (sole proprietor, standard, low-volume mixed).8

Carrier fees, per message

On top of the registry fees, each US carrier charges a fee on every A2P message segment. The carriers do not publish a public schedule we could find; platforms publish what they pass through. We use Twilio's table because it lists each carrier separately; other platforms publish similar ones, and this is not a recommendation of any provider.9

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These are added to the platform's own price (on that page, $0.0083 per outbound SMS segment), and the same page notes a $0.001 fee on messages that end in a "Failed" status.9 The platform says carrier fees are "passed through by Twilio to our customers with no added cost" and that T-Mobile also charges on inbound messages.8

A worked example

A small business with a tax number, one low-volume mixed campaign and 300 outbound text segments a month, on that schedule: $4.50 brand plus $15 campaign vetting once; then $1.50 a month for the campaign, about $2.49 in platform charges and roughly $1.05 to $1.50 in carrier fees for the 300 segments. Call it $25 for the first month and under $6 a month after that, before the cost of the number itself.89

Our view: for a small sender the fees are not the barrier. The barrier is the paperwork, the weeks of review, the resubmission fees when a name does not match, and the fact that a business only learns it got something wrong when messages stop arriving.

Unregistered texts are blocked, not just filtered

Unregistered business texts on local numbers used to be surcharged and filtered more heavily (one platform's documentation still warns of "additional carrier fees for sending unregistered traffic").10 Today they are blocked, though the platforms did not all switch on the same day.

• Twilio: "All unregistered messages bound for the U.S. from +1 10DLC numbers are blocked starting September 1st., 2023."11 The error it returns reads: "Twilio blocks messages to U.S. numbers when you send from a +1 10DLC number that is not associated with an approved A2P 10DLC Campaign."13
• Telnyx: "From February 3rd 2025, any 10DLC traffic which is not registered will be blocked altogether." The same page warns that "virtually all SMS and MMS sent by a business—even if manually triggered by a human—is considered A2P."12

Registration does not guarantee delivery. A registered message can still be "filtered (blocked) by Twilio or by the carrier" if it is "identified as spam or unwanted messaging" or "flagged as objectionable".14 The CTIA principles leave that discretion with every provider in the chain.1

Toll-free numbers: verified or silent

Toll-free numbers (the FCC lists the codes as "800, 888, 877, 866, 855, 844 or 833")19 can carry texts, but only after verification. CTIA's principles say that "Authority to Text-Enable Rests with the Toll-Free Voice Subscriber": only the holder of record of the toll-free number for voice can enable texting on it.1

Twilio required all US-bound texts from toll-free numbers to be "fully verified or pending verification" from 8 November 2023.15 The pending allowance has since ended across the industry: Sinch's documentation says unverified and pending toll-free numbers "are subject to industry-wide message blocking" and that "all toll-free numbers, regardless of the use case, must be Verified to originate traffic."16 Twilio's documentation says toll-free numbers "can't send SMS messages to the United States and Canada until you've completed toll-free verification."18

What verification asks for, from one platform's API: business name and website, use-case categories and summary, a production sample message, images of the opt-in flow, the opt-in type (verbal, web form, paper form, text, QR code or import), estimated monthly volume, and a business registration number, authority and country for every business type except sole proprietors. Optional fields include the opt-in confirmation text, a sample HELP reply, the privacy policy and terms URLs.17

Toll-free verification has no TCR-style monthly campaign fee in the platform documentation we read, and it covers Canada as well as the US.18 We think it is the simpler lane for a small business that texts at low volume and is content with a national number rather than a local one. The trade-off is that the texts come from an 800-series number, not the local number customers already know.

Short codes, in the US and in Canada

Short codes are the oldest sanctioned lane. CTIA describes them as "non-NANP addresses of 5 or 6 digits typically used by businesses, entities, or organizations for high-volume communications", with upfront vetting and ongoing auditing.1

United States

The US registry is run by the Common Short Code Administration, an LLC governed by CTIA. A selected code leases at $1,000 a month and a random one at $500, for 3, 6 or 12 months, and "These fees are non-refundable regardless of whether any wireless service provider agrees to activate your code."20 Programs are audited against CTIA's Short Code Monitoring Handbook (version 1.9, effective 2 August 2023), which says that "At a minimum, Message Senders must respond to messages containing the HELP keyword with the Program name and further information about how to contact the Message Sender."21

Canada

Canadian short codes are administered by the Canadian Telecommunications Association, which was "formerly named the Canadian Wireless Telecommunications Association"23 (CTIA's 2023 principles still use the old name).1 Its terms, from txt.ca:22

• A non-refundable deposit of $1,500 plus GST/HST covering the first three months, then $350 plus GST/HST a month; a reduced rate for non-profits and charities.
• Two or more separately owned carriers must agree to take part, and each carrier can decline any program.
• An initial 12-month lease; provisioning "in 3-6 weeks" from approval; applications reviewed weekly.
• An annual carrier "brownout" with no new provisioning: for 2026 the cut-off for provisioning by all carriers was Thursday 22 October 2026, and later applications go into January 2027.

The Canadian Common Short Code Compliance Policies (version 2.1, January 2026) are stricter than the US handbook on language. Five keywords are mandatory on every program, "regardless of price point, intended audience, message frequency, subscription status, or commercial availability": STOP, ARRET, HELP, AIDE and INFO. They must work in English and French "regardless of the intended audience", and a reply to them may be no more than one 160-character segment.23 The policies also warn that "What may be allowed under CASL may not be allowed under the Canadian CSC Compliance Policies."23

Consent, STOP and HELP: what the industry expects

The CTIA principles set three levels of consent by type of message:1

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Beyond that table, the principles expect:1

• Records of consent (timestamp, medium, the wording shown, campaign, IP address, number, who consented), one opt-in per campaign, and no rented, sold or shared lists.
• Opt-out by any reasonable wording. "Standardized 'STOP' wording should be used for opt-out instructions, however opt-out requests with normal language (i.e., stop, end, unsubscribe, cancel, quit, 'please opt me out') should also be read and acted upon".
• One confirmation, then silence: "one final opt-out confirmation message per campaign", after which "No further messages should be sent".
• HELP instructions or customer-care details in the confirmation for recurring programs, and links whose websites name the owner with contact information "such as a postal mailing address".

What US law adds

The TCPA treats a text as a call

The Telephone Consumer Protection Act restricts calls made with an autodialer or an artificial or prerecorded voice to mobile numbers without prior express consent, and gives recipients a private right to "$500 in damages for each such violation", trebled for wilful or knowing violations.24 The Supreme Court settled that texts are covered: "A text message to a cellular telephone, it is undisputed, qualifies as a 'call' within the compass of §227(b)(1)(A)(iii)."25

The autodialer half of that rule is narrower than it used to be. In 2021 the Court held that "a necessary feature of an autodialer under §227(a)(1)(A) is the capacity to use a random or sequential number generator".26 We think most text-back tools reply to the number that just called rather than generating numbers, but whether a given tool is an autodialer depends on how it actually works. We do not offer a view on any product; that is a question for counsel.

Do-not-call rules apply to marketing texts

The FCC's rules apply the do-not-call and calling-time rules to "telephone solicitations or telemarketing calls or text messages to wireless telephone numbers".27 The FCC's December 2023 order "codifies that Do-Not-Call list protections apply to text messaging, making it illegal for marketing texts to be sent to numbers on the registry."28 A telephone solicitation excludes a message to someone with whom the sender "has an established business relationship", which includes an inquiry by that person "within the three months immediately preceding" the message.27

Revoking consent: STOP, ten business days, one confirmation

The FCC's February 2024 consent order rewrote how opt-outs work.29 The current rule says replying "stop," "quit," "end," "revoke," "opt out," "cancel," or "unsubscribe" is "a reasonable means per se to revoke consent"; any other reply must be honoured "if a reasonable person would understand those words to have conveyed a request to revoke consent"; requests must be honoured "within a reasonable time not to exceed ten business days"; and a sender "may not designate an exclusive means to request revocation of consent."27 One confirmation text is allowed if it "does not include any marketing or promotional information"; sent "within five minutes of receipt, it will be presumed to fall within the consumer's prior express consent."27

These took effect on 11 April 2025, except the requirement that an opt-out in reply to one type of message covers "all future robocalls and robotexts from that caller on unrelated matters", which the FCC has deferred to 31 January 2027 while it reconsiders it.30

Carriers must now block some texts

The FCC's first rules aimed at texts (adopted 16 March 2023) require mobile providers to block texts purporting to come from numbers on a reasonable do-not-originate list: numbers whose subscriber asked for blocking, invalid numbers, unallocated numbers and unused numbers.327 Mobile providers must give senders a point of contact "to resolve complaints about erroneous blocking".27 The December 2023 order added that, on a Notification of Illegal Texts from the FCC's Enforcement Bureau, a terminating mobile provider must block "all texts from the identified number or numbers".2728 Those blocking rules cover SMS and MMS on wireless networks, not over-the-top services such as iMessage, WhatsApp or RCS.3

The lead-generator rule that did not survive

The December 2023 order also required lead generators to collect consent "one seller at a time".28 The Eleventh Circuit vacated that part on 24 January 2025,31 and the current rule has no one-to-one requirement;27 many 2024 summaries are out of date on this.

Canada: no registry, but CASL

No 10DLC registration for Canadian traffic

Canada has no equivalent of The Campaign Registry for domestic texts. TELUS tells its business customers: "If you're a Canadian company and want to send SMS messages to your Canadian customers, you don't need to register with the TCR at this time." The same page says a Canadian company texting US customers must register, because "U.S. mobile carriers now require you to register your brand, campaign and number assignments".32 The US rules follow the recipient's number, not the sender's country.

Delivery is not easy, though. Twilio's Canada guidelines say "Canadian mobile carriers enforce strict filtering on A2P messages" and recommend "sending application-to-person (A2P) traffic over short codes or verified toll-free numbers".33 Your platform may also set its own requirements for Canadian long-code traffic, so ask what it needs from you.

CASL covers texts

Canada's Anti-Spam Legislation defines an electronic message as "a message sent by any means of telecommunication, including a text, sound, voice or image message".34 A commercial electronic message is one whose purpose, or one of whose purposes, is "to encourage participation in a commercial activity".34 To send one, three things are required:34

1. Consent, express or implied.
2. Identification of the sender and of anyone on whose behalf it is sent, with contact information valid "for a minimum of 60 days after the message has been sent".
3. An unsubscribe mechanism that works "at no cost" through the same electronic means where practicable, and that takes effect "without delay, and in any event no later than 10 business days".

The CRTC's regulations require the message to give the sender's business name and "the mailing address, and either a telephone number providing access to an agent or a voice messaging system, an email address or a web address". Because that rarely fits in a text, the regulations allow it to sit on a web page reached "by means of a link that is clearly and prominently set out in the message."35 The CRTC's guidance on SMS: "the user should have the choice between replying to the SMS message with the word 'STOP' or 'Unsubscribe' and clicking on a link that will take the user to a web page where he or she can unsubscribe".36

Implied consent comes mainly from an existing business relationship: a purchase within the previous two years, or "an inquiry or application, within the six-month period immediately before the day on which the message was sent".34 Some messages need no consent at all, but still need identification and an unsubscribe mechanism: for example, one that "solely" provides a quote or estimate the recipient asked for, or that "facilitates, completes or confirms" a transaction they agreed to.34

For US businesses texting Canadians: the Act applies when "a computer system located in Canada is used to send or access the electronic message"; in our reading, a phone in Canada on which the text is read is such a system.34 The sender bears "the onus of proving" consent, and the maximum administrative penalty is "$1,000,000 in the case of an individual, and $10,000,000 in the case of any other person."34

Where small businesses get hurt: missed-call text-back

Automatic text-back ("Sorry we missed your call, how can we help?") is how many small businesses start sending A2P traffic without knowing it. What can go wrong, roughly in order:

1. The number cannot text, or texts through someone else. Voice and text on one number can be handled by different providers. CTIA expects a sender to text-enable only a number it "has been assigned by a provider of telecommunications or interconnected Voice over Internet Protocol (VoIP) services", after an authentication process.1 Whoever sends the texts has to be able to show the number is yours.
2. Nobody registered a campaign. The feature is switched on and the texts are blocked on the platforms that block unregistered traffic.1112 Nothing tells the caller; the business may not notice for weeks.
3. The brand fails verification. The legal name does not match the EIN or Business Number exactly, and every identity resubmission is charged again.56
4. The message drifts into marketing. A reply that only answers the call is one thing; add "book now for 10% off" and, in CTIA's words, a call-to-action "may place the message in the promotional category", which expects express written consent.1 In the US, that can also make it a telephone solicitation subject to do-not-call rules unless an exception such as a recent inquiry applies.27
5. STOP is not handled. The tool sends the reply but nobody wires up opt-outs, or it treats only the exact word STOP as an opt-out. The FCC rule lists seven words and requires any reasonable wording to be honoured.27
6. Staff carry on from their own mobiles. CTIA counts an employee texting on the business's behalf as Non-Consumer traffic,1 so this does not avoid the rules; it just moves the messages to a channel nobody registered.

Our reading of consent for a text-back (not legal advice): a missed call is not a text, so the reply does not fit CTIA's "conversational" category, where the consumer sends the first message.1 It is closest to "informational", where the person has asked to be contacted. One short, non-promotional reply that names the business and says how to opt out is the defensible version. In Canada, a call asking about your services is plausibly an inquiry that creates implied consent for six months,34 but the message still needs identification and an unsubscribe mechanism.35 Anything more, such as follow-up sequences, offers or review requests, needs consent you can prove.

The missed-call text-back checklist goes through implementation and testing step by step. If you also want one number for both calls and texts, the calls-and-texts checklist covers how to confirm which provider handles each channel before you print the number. The missed calls hub covers alternatives that do not involve texting at all.

Our view

We think the US system is a reasonable answer to a real problem, built so that most of the cost falls on the honest small sender. Three observations from the sources above support that.

First, it works through the supply chain rather than through law. Because texting is not a common-carrier service,3 carriers can require registration as a condition of carrying traffic, and they did. The result is effective (unregistered traffic is simply blocked) but opaque: TCR approves nothing, the CSPs and aggregators in between do,5 and a business only deals with the first link in that chain.

Second, the fees are small and the friction is large: a few dollars a month,68 but weeks of review4 and paid resubmissions over a mismatched name. A large sender absorbs that; a two-person trade business often does not know it applies.

Third, registration is not delivery. A registered, vetted sender can still be filtered.14 The "trust score" is a vetting input to throughput,56 not a promise that any message arrives.

Canada chose to regulate the sender's conduct by statute and to leave domestic long-code traffic to carrier filtering. It is cheaper and simpler to start, with a much steeper legal penalty for getting consent wrong.34

If your business only needs customers to reach you, a phone line that answers and routes calls well avoids all of this. If you do need texting, before you switch it on: pick the lane; make the legal name match your EIN or Corporations Canada record exactly; write down where and how people opt in; handle STOP and its synonyms (and ARRET and AIDE on a Canadian short code); keep messages to the registered use case; and use a platform that shows you the campaign wording it submitted and every blocked or filtered message. Treat the first month as a test.152327