Up until this point, cannabis brands and dispensaries have used person-to-person (P2P) messaging, shortcodes and toll-free numbers to send texts to their customers. Businesses sending A2P messages must register for 10DLC to continue sending text messages.
10DLC is an application-to-person (A2P) messaging channel created by Mobile Network Operators (MNOs) that uses local, 10 digit phone numbers to enable secure business-to-person messaging.
How A2P messaging works
Why the switch?
It’s all about consumer protection and trust. MNOs must ensure their customers receive trustworthy texts devoid of unwanted spam, harmful content or messages.
In the past, businesses leveraging short code or P2P messaging have faced heightened compliance risks, limited throughput and sometimes termination of services for two main reasons.
The first is because businesses with short codes often shared the same five or six-digit phone numbers with thousands of other businesses. So if a bad actor began using that short code to send spam or non-compliant content, MNOs would likely shut down that number.
The second is because some businesses were using unregistered P2P phone numbers to send harmful or malicious content that violates SHAFT regulations (Sex, Hate, Alcohol, Firearms, and Tobacco).
The switch to 10DLC is a win-win for all.
Avoid fines, fees and penalties
The cost of non-compliance is notoriously high, especially in highly regulated industries.
P2P messaging shut-off and the implementation of fines and penalties for non-compliance will begin no later than January 1, 2022.
Businesses can also face penalties using evasion techniques such as snowshoeing, the practice of spreading messages over multiple numbers to evade filters and throughput limits.
T-mobile – a leader driving the switch to 10DLC – has already outlined penalties that violate their code of conduct:
$10,000 fine for sending messages prior to 10DLC authorization
$10,000 fine for each unique instance of SHAFT and TCPA violations
$1,000 fine for using evasion techniques, such as snowshoeing
$10 per message for sending P2P messages after the switch
Here are the three steps you must complete to continue communicating with your customers via text:
1. Register for 10DLC
If your brand or dispensary leverages text messaging to communicate with customers, you must register for 10DLC messaging with The Campaign Registry by January 1, 2022. Campaigns from "unverified" businesses will be automatically deactivated after this date.
2. Apply for a brand verification score
To apply for a brand verification score, you must work with one of The Campaign Registry’s verified vetting partners. Your score is calculated by a number of factors such as your tax history, age of your EIN, and by running a background check to ensure there is no prior history of TCPA violations or complaints. The brand verification scores are important because it will determine your campaign’s throughput (the number of texts sent per minute, hour or day).
3. Provide sample text messaging content for approval
You must provide The Campaign Registry with sample text messaging content for pre-vetting and approval so that MNOs will already know your content is ready to be sent to customers. Because cannabis is still classified as SHAFT content, the samples you provide will need to be very carefully worded. For example, you will be required to remove cannabis-specific terms and keywords. Even if your business has a name relating to or containing a cannabis keyword, you must avoid using it. You must also make sure any links or URLs should direct to a clean, cannabis-free landing page.
Start leveraging 10DLC today
As a campaign service provider (CSP), Fyllo works with The Campaign Registry to set up your registration, obtain your brand verification score and prepare compliant sample content to submit to The Campaign Registry for approval on your behalf. From setup to strategy and execution, our team of industry experts is here to help every step of the way.
The information provided is current as of November 8, 2021, and subject to change.