Texting customers from a business number: the rules, in plain English

Why carriers make you register before you text

Regular 10 digit phone numbers were built for people texting people. When businesses started sending texts from software through those same numbers, spam came with them. Twilio's documentation explains that unregistered 10 digit numbers were abused by spam and unsolicited messaging, which made many consumers distrust texts. Carriers responded with a registration system called A2P 10DLC (application to person, 10 digit long code).

Registration has two parts. The brand says who is sending: your business name and, for most brand types, your tax ID. The campaign says what you're sending and how people opt in, opt out, and get help. Registered senders get less carrier filtering and more sending capacity.

Skipping it isn't really an option anymore. Twilio, one of the largest messaging providers, blocks messages to U.S. numbers sent from a 10DLC number that isn't tied to an approved campaign. Toll-free numbers have a parallel process called toll-free verification, and Twilio's docs say a toll-free number can't send texts to the United States and Canada until verification is complete.

• Texting from your personal cell to a few customers by hand is person to person texting. It isn't what registration covers.
• Texting from business software (reminders, on-the-way texts, review requests, a shared business number) is application to person, and the number needs to be registered or verified.

Get consent that fits the message

The wireless industry's guidelines, the CTIA Messaging Principles and Best Practices, sort business texts into three kinds. Each needs a different level of permission.

1. 1

   Conversational: implied consent

   The customer texts you first and you reply with what they asked for. "Do you have anything Thursday?" "Yes, 2 PM works." No extra permission is expected.

2. 2

   Informational: express consent

   The customer gives you their number and agrees to texts for a specific purpose, like appointment reminders or on-the-way alerts. They can say yes on a form, over text, or out loud on the phone.

3. 3

   Promotional: express written consent

   Anything selling something: a spring special, a coupon code, a win-back offer. CTIA says the customer should agree in writing first, such as signing a form or checking a box. Adding a coupon to a reminder can turn it into a promotional text.

Federal law lines up with this. The FCC's consumer guide says texts sent to a mobile phone with an autodialer need the owner's prior consent, that commercial texts require written consent, and that for informational texts consent may be oral. Whether your particular texting setup counts as an autodialer is a legal question for your counsel. The CTIA guidelines ask businesses to get consent regardless of whether those rules apply.

Write down how you got the yes. CTIA suggests keeping the date and time, how it happened (web form, paper form, text keyword), the wording the customer saw, the phone number, and who agreed. A booking form with a checkbox does most of this for you.

Honor STOP, every time

This is the rule that matters most day to day. Under the FCC's rules (47 CFR 64.1200), a customer can take back their consent by any reasonable method. Replying to a text with "stop," "quit," "end," "revoke," "opt out," "cancel," or "unsubscribe" counts automatically. The request has to be honored within a reasonable time, not to exceed ten business days.

• Read plain language too. CTIA says "please opt me out" and similar wording should be acted on, and capitalization or punctuation doesn't change it.
• Send one confirmation, then nothing. A single text confirming the opt-out is allowed. The FCC rule presumes it's fine if it goes out within five minutes. CTIA says no further messages after that confirmation.
• Tell people how to stop. CTIA asks senders to state in the message how to opt out, using standard STOP wording.
• Keep the list. Record opt-outs so a teammate or an automation doesn't text that person again next month.

The hard part for a small team isn't knowing the rule. It's making sure a STOP sent to one person's phone reaches everyone else who might text that customer. That's the best reason to text from one shared business number instead of five personal cells.

Quiet hours: when not to text

The FCC's rules bar telephone solicitations to a residential subscriber before 8 a.m. or after 9 p.m., local time at the called party's location. Some states set their own windows. Florida's law on commercial telephone solicitation calls, for example, uses 8 a.m. to 8 p.m. in the called person's time zone.

Those rules are written around calls and solicitations, and how they apply to texts is a question for your counsel. The practical habit is simple: keep marketing texts to normal daytime hours in the customer's time zone, not yours. A coach with clients in three time zones should check before a 7 a.m. Eastern blast goes out to someone in California at 4 a.m.

Service texts are different in spirit. A customer who booked a 7:30 a.m. visit expects an on-the-way text at 7:10. Use judgment, and keep anything promotional out of those early messages.

What not to send

Carriers filter on content as well as on registration. The CTIA guidelines ask senders to keep out content that is misleading, deceptive (like phishing), harassing, threatening, or that doesn't meet age-gating requirements. Some everyday versions of that for a service business:

• Bought or borrowed lists. CTIA says not to text lists that were rented, sold, or shared. Consent belongs to the business that collected it.
• Generic link shorteners. CTIA says links shouldn't hide who you are, and that a shortener should be one dedicated to your business. Use your own domain.
• Unnamed messages. Start with your business name so the customer knows who's texting.
• Promotions slipped into reminders for customers who only agreed to reminders.
• Sensitive details a customer wouldn't want on a lock screen, like a full card number or a gate code they didn't ask you to text.