Prior Context
The recent changes to Application-to-Person messaging via standard 10-Digit Long Code (A2P 10DLC) messaging that are being enforced at the SMS carrier level, have caused the cannabis industry to be subjected to increasing scrutiny. A2P 10DLC is a new set of regulations enforced by carriers as a way to limit spam texts, scam messages, and unwanted marketing on SMS carrier networks. Additionally, cannabis has been placed in the Sex, Hate, Alcohol, Firearms, and Tobacco (“SHAFT”) category of messaging content by SMS carriers. The classification of cannabis as SHAFT-related content has intersected with new rules around A2P 10DLC messaging enforced by carriers resulting in significant changes to the way the cannabis industry can send and receive communications over SMS.
Changes Effective October 1st
T-Mobile has taken a hard line for their stance on enforcement of A2P 10DLC requirements. Their approach goes far beyond that taken by AT&T or Verizon who have largely chosen to loosely enforce requirements or extend deadlines for A2P 10DLC campaign registration requirements. T-Mobile has chosen to begin enforcing the following fines on their network to incentivize traffic on their network to become registered:
Campaign Service Activation - this pass-through fee is charged by T-Mobile for each campaign provisioned ($50) [Note: This fee occurs any time a campaign is created regardless of whether it violates SHAFT requirements]
Campaign: A 10DLC campaign contains information about your use case for SMS messaging
A campaign is required to be created any time a use case for messaging changes
Campaign Service Migration - this pass-through fee is charged by T-Mobile for each campaign provisioned ($50)
NNID Registration and Setup - this pass-through fee is charged where a customer requires the creation and use of an NNID separate from the default NNID that Telnyx provides to be used for new 10 DLC programs. ($2,000)
NNID: Net Number ID
Non-compliance fees:
Text Enablement - this pass-through fee applies if T-Mobile receives a complaint where you or your message sender text-enables a 10-digit NANP telephone number and sends messages prior to verification of message sender ownership. ($10,000)
Meaning the fee will be charged if messages are sent over a number that is not registered to a 10DLC campaign
10DLC Messaging Program Evasion - this pass-through fee applies if a program (per incident) is found to use evasion techniques like snowshoeing, unauthorized number replacement, and dynamic routing. ($1,000)
Dynamic routing is what is currently utilized by AlpineIQ to evade many of the issues seen with SMS filtering today
Content Violation - T-Mobile may charge this pass-through fee for each unique instance of the third or any subsequent notification of a content violation involving the same content provider. Content violation is defined as sending messages in violation of the rules in the Code of Conduct, and are usually SHAFT violations (Sex, Hate, Alcohol, Firearms, Tobacco) but would also include spam or phishing, or messaging that meets the threshold of a Severity 0 violation per the CTIA Short Code Monitoring Handbook. ($10,000)