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Thank you for sharing what worked with Twilio. I have quite a few trunks with them now, and had completely abandoned all SMS capabilities on every number because I couldn’t get anything approved and decided to quit wasting time.
For the record, it was never about creating ad campaigns or bulk SMS, it was intended only for a couple of my clients to notify their own customers that something was ready. One switched to a general mobile phone to allow both calls and texts from the same number, and the other moved to a paid service instead.
I’ll file your info away for the next time someone wants to SMS from their primary line and hope it still works!
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I have spent the last 5 years, along with @tonyclewis, making posts in this community about the changes being imposted by the FCC or new federal laws. Those post mostly went ignored or had replies from people saying it didn’t concern or impact them. Of course, down the road the same people were finding out that yes it did concern and impact them.
and if you look back I was also making the same arguments alongside Tony (and by default you). In fact that’s how Tony and I started talking, he reached out to me after one particular thread where he and I were arguing the same thing against a bunch of people who had it wrong about what the definition of a reseller was and how the STIR/SHAKEN rules were absolutely applying to them.
I really didn’t understand who @tonyclewis was at the time until that offline conversation and he invited me to become a partner with ClearlyIP. That solved all my problems with this stuff and I haven’t looked back. ClearlyIP has been incredible to work with, their entire staff from sales, support, porting and billing have been awesome to work with and Tony is always there and extremely generous with his industry knowledge/guidance any time I’ve had a question.
All that said, I still say this entire process with 10DLC has been a mess with things changing almost quarterly at one point. The latest of which is the 12/1/24 deadline push to sometime in feb 2025. Did the OP make his own life more difficult than it had to be? (EDIT: actually I think I’m mixing responses here with another parallel thread about it being difficult to setup 10DLC?) Probably but honestly if it weren’t for the staff at ClearlyIP being so knowledgeable and helpful my experience with setting up the few campaigns I have would have been a mess too I think. Perhaps the people over at Twillio just aren’t as helpful with it but having never used Twillio I can’t really say.
Giving people a little grace here, keeping up on the rules/regs/policies etc in this industry is not an easy task especially when you can easily get 7 different interpretations online of what any one of those things are, mean, impose and apply to.
That said if you are involved with managing or setting up SIP trunks for a client, my advice is get a good SIP trunk company to partner with and have them serve your customer directly. Obviously I’m a big fan of ClearlyIP so that’s who I’d recommend if asked.
It’s pretty easy. In a rough nutshell, the FCC will make a proposal, that proposal will go through a period of comments and then the order will be made. That order will then be published to the Federal Registry and once is it published there it generally has a 30 day period before it goes into affect. This is why providers have compliance officers and legal teams for all of this. Either in-house or external. So they can get legal advisement on these rules and what they need to do to be in compliance.
I mean while everyone seems to be going on about the 10DLC that was yesterdays news for pretty much all the providers out there. Right now the big concern from providers is the new Disaster Reporting regulations that we need to all comply with by Feb 20th 2025. We’re waiting on the other shoe to drop for the 911 reporting requirements which will include providers reporting they are having a 911 outage to the FCC and to all the PSAPs they serve.
Part of the problem with 10DLC is the same problem STIR/SHAKEN and the RMDB had. In the beginning it was a simple process that trusted the providers to do what was required. The vetting/approval processes where more automatic, I was able to register 10DLC in the beginning with little to no problems. But just like STIR/SHAKEN, they found a lot of the submissions to be lacking details and data.
So basically, providers and CSP’s acting in bad faith reduced the level of trust that the FCC had given us all. We’ve now ended up with automated processes having more manual review, the onboarding requiring more work and probably more costs being incurred because people just half-assed their efforts of compliance.
This is also why, in regards to STIR/SHAKEN, that we now are going to have to do annual filings, re-certification and a new annual cost for it. So now I have to do more work and pay more money because VoIP providers (it’s always the VoIP providers) can’t make an effort to follow the rules.
Guess what happens when a provider has their underlying costs increased not just because of the extra work they need to do but also for fees/charges being introduced to continue operating? Costs to the end users can go up or more costs will be passed on to the end users.
Hell, we have to follow Known Your Customer (KYC) now and that can increase the on-boarding costs of a new customer.
It’s “Easy” for you, you’re in it 100% of the time, it’s your job (I assume). If I qualify as a “VoIP provider” by your standard then the situation for me is a bit different. It’s not my core business, it’s a tie in and just another aspect to the IT work we do for our clients. I don’t have a vision on all that you do. Were/Are there purposely bad actors out there? definitely, no doubt.
Part of the issue, from my point of view as a former “VoIP provider,” is that there were also some not so scrupulous wholesalers out there that had zero requirements to set up a reseller. “You want to resell sip trunks? Sure no problem! sign here and have fun!” Early on that was my experience, not a single vetting question asked and to my mind, there should have been because they knew better what was involved.
As you say, the processes used to be easy until bad actors “half assed” it. I used to re-sell SIP Trunks I bought wholesale and did try to understand and follow the rules (consulting with industry lawyers/firms.) When STIR/SHAKEN came out is when I got out because the requirements and costs involved were just not worth the effort and finding a straight answer on how to implement it all was difficult to say the least.
It was during this time that I was arguing with people on here (alongside Tony) that they were interpreting things wrong and that if you were reselling wholesale sip trunks you absolutely were subject to and directly responsible for the STIR/SHAKEN rules primarily because KYC couldn’t be passed through to the wholesaler as many assumed and argued.
All that said, it’s no excuse for not knowing the laws/regs/requirements and so as things changed I did my best to understand it all, navigate it and eventually came to the conclusion that it wasn’t worth the money/effort to keep doing it ourselves for the level of revenue vs risk it produced. Thus the partnership with ClearlyIP which we’re more than happy with. In the end the drop in revenue from no longer reselling directly is nothing compared to the drop in risk from running afoul of the FCC rules/regs.
I’m aware of the new disaster reporting regs and am glad I’m insulated from it. Even though we don’t resell sip anymore I still try to keep up on the industry news and, as said before am grateful for the access I have to the ClearlyIP staff and Tony to authoritatively answer questions I may have.
Anyone on these forums would do well to read and pay attention to what @tonyclewis and people like yourself post with regards to the industry, even if you’re just an end user running your own PBX, there are 911 rules that apply to you there as well.
Do you charge your customers directly for voice services? Then you are a VoIP Provider. It’s not my standard, it’s the FCC’s standard.
You are correct. We used to, now we do not, we gladly leave that up to CIP now.
I think early on (2010-12) a lot of the confusion was who was a CLEC and who wasn’t. I know for myself, my early understanding (right or wrong) was that you had to own the network that the traffic travelled over to truly be a CLEC and therefore if you didn’t have that you weren’t and a lot of the rules didn’t apply. I think a lot of people here understood it the same way mixing VoIP provider and CLEC incorrectly.
I would like advice from this thread as a lot of this applies to me. I run a PBX and use Twilio. I used to use their SMS gateway until this nonsense started.
We have some mobile phones. I can send and receive SMS messages on them with no problem. But on my home landline phone, which is under Twilio, I am now blocked.
I’m supposed to register a campaign and all that stuff and pay a fee. Why?
Why don’t I have to register a campaign on my t-mobile handheld phone?
What the hell kind of “campaign” and “business” to I need to be able to send a quick text message to my wife who is out shopping?
I gave up and started telling people just don’t use SMS, but then I saw this thread and it opened old wounds.
Twilio has no option for a family like ours to just send simple SMS messages (like I did for 10 years prior). I even opened a ticket with them and they were clueless. So I setup a sole proprietorship and registered tax numbers and starting filing all this useless garbage to satisfy their bureaucracy, but I’m pretty fed up at this point.
Again, I’m not a corporation, I’m a dad. I don’t have a campaign. What the hell.
We previously had a Zoom Phone account. They made us go through the campaign nonsense, though they provided considerable help. For example, see
My first attempt was rejected but support provided additional help. Per their advice, I set up the ‘privacy policy’ link to say:
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.
All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We do not sell any data to any third parties.
and also added a ‘contact us’ link with a phone number and email address.
The campaign was then approved. Luckily, this all happened before they started blocking messages.
The Zoom account had an issue unrelated to SMS and we switched to Intermedia Unite.
There, we signed an agreement stating that all our messages are conversational and we will not send any by automated means. They allow SMS and MMS without a campaign.
You raise an interesting point if I understand your situation properly. What I understand and correct me if I’ve got it wrong here.
You have a PBX that you use entirely privately for your family. No business involved, no customers… you’re just using it like a super charged home phone.
Texting/sms from this system would be for personal use, family, friends, other personal messages (you’re Dr, local nail salon sending appointment reminders to you etc…)
why should YOU be required to register a campaign. Clearly there is nothing in the law stopping you from having a 10DLC for personal use. Nothing stoping you from setting up a PBX for personal use.
And this is where I was going earlier in the convo with the idea that the FCC just pushed off their “authority” or “responsibility” to the mobile carriers.
The clear answer from the mobile carriers is: Get a cell phone…
I find it odd and a bit disingenuous and honestly a conflict of interest that there is zero campaign requirements for texting “customers” from a mobile phone but the minute it’s a 10DLC. Unless there are rules/safeguards in place to prevent someone from hooking up a cell phone for robo-texting. I would imagine it wouldn’t take a rocket scientist to get an android phone and create an robo-text app, fill a room full of them and cry havoc…
I’m clearly making some assumptions here so please educate me if I’m not understanding the situation properly. I know there are people here who understand the in’s and out’s of all this much better.
Because it is difficult to send high volume, repetitive messages if you have to do them by hand.
However, I’d note that the terms of service of my domestic mobile account, not in the USA, say they they can block me if I send the same message to multiple people, and they do, apparently, monitor for this. You can’t even implement a neighbourhood watch type alert system.
Whilst this indicates that some control can be applied without the need for a registration system, it does show that even personal mobiles can have restrictions on their use of SMS, outside the USA.
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You get it. Let me answer your point about “get a cellphone”.
First, we don’t want cellphones in the house. We don’t want more unnecessary RF/EMF.
Next, I don’t want to try to use a micro-screen and microscopic buttons to try and type, with the absurd spell checker changing everything I write. I have a proper desktop computer and 30 inch 4k display, I’ll use that.
Next, cellular doesn’t even WORK in my house. You would have to go down the road and up the hill to even get a reliable signal.
Next, my home phone number has been in use for over 30 years. That is the ONLY number people know. No one uses my mobile numbers except “extended car warranty” notifications. We use Unified Communications. You call my main Twilio number and the call gets routed to the proper ring groups, or maybe to a SIP app running on any one of our families mobile phones if they are off-prem. Hell, I don’t even know the cellular phone numbers. I would have to go look them up.
I’m not expecting a solution. I see big businesses are getting worse and worse and there is no fixing it. I just wanted to vent. For my family, we use our own on-prem XMPP Jabber network. The only thing SMS would be for is what you said, dental appointments, stuff like that. Sadly, many people are stuck on “everything has to be a cellphone app”. Yeah, not doing that. I’ll go live in the woods before that happens.
Thanks for listening.
All VoIP numbers fall under 10DLC, which is the replacement for Short Codes, because they use APIs and other automated methods for sending and receiving the messages. There is no 1:1 relationship with a VoIP numbers as there is with a Mobile number.
Mobile numbers are categorized as Person-to-Person (P2P) meaning that a person with a personal device is sending a text to another person (ie mobile number to mobile number). VoIP numbers are categorized as Application-to-Person (A2P) which means an API or other application is used to send or receive texts as well as no 1:1 relationship. That means I could have a single VoIP number but 10 instances of Textable on 10 different phones all sending as the same number.
VoIP Providers can register as a P2P provider, Google Voice is one, meaning that it is meant for personal use and personal use only. It also means you can only use the provider’s interfaces which cannot allow for any mass texting or even 3rd party integration (ie. apps like Textable).
Now yes you could get a SIM card and do some hacking and setup a method to mass send texts, however, if A2P traffic is found going over P2P or Mobile:Mobile peers you will be fined by the FCC for it (like upwards of $10K). So please feel free to FAFO with this and see what happens.
Here’s the base issue with this, Twilio is not a residential/consumer carrier. Sure they will be more than happy to provide you services but you are not their market space. They have no desire to cater to residential users. The texting services provided by Twilio are 100% A2P/10DLC and thus are subject to those rules. The best you could do is become a Sole Proprietor which has some limitations but Twilio supports Sole Proprietor Brands/Campaigns.
This goes the same for a lot of the providers out there like Flowroute, Telnyx, etc. they are not marketing to residential/consumers they are business level providers. Yes, you can sign up and use them for personal use but again, they do not cater to the dad at home that wants to send a text to his wife saying “Can you grab a six pack while out?”
What makes this even more a kick in the junk than STIR/SHAKEN for calls is that a text message can be more than SPAM, it can be more than a “Auto Warranty” phishing scheme. The bad actors can send malicious attachments or links containing malware or other bad things that can end up on the phone or computer (since there is Text-to-Email delivery). That little additional factor makes something like 10DLC even more needed.
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Uhm, no it’s not. Rules like what 10DLC has already exist for Short Codes and Toll Free Messaging (comes from a TF number). Mass messaging/marketing has existed for decades but it was limited to Short Codes and Toll Free all of which has rules/regulations to follow including registering their company/brands for sending messages not to mention paying costs for such things.
They took an existing thing and modified it for the use of 10DLC with VoIP numbers. This really isn’t something new, it’s just new for you.
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Great info @BlazeStudios, thanks!
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