Carriers have recently added new requirements to 10DLC campaigns. These new requirements are applicable immediately. Vonage has been notified that the campaigns registered prior to the announcement of the changes, but still undergoing the review process will also need to adhere to the new requirements. Please read below to see a quick summary of the update.
Description of the changes
There are three areas impacted by new requirements, or a re-enforcement of the existing guidance:
Most of the changes are taking place under the message flow section of 10DLC campaigns. Carriers now require customers to provide documentation outlining the exact call-to-action (including all the legal mentions and required statements) for each of the methods allowing subscribers to provide consent and subscribe to the campaign.
Customers are asked to use the hosting file service of their choice to upload the documentation required, and share the link to those documents in their campaign message flow. Please note that the link should allow for multiple accesses until the campaign has been reviewed and approved by Vonage and each of the carriers.
Requirements applicable to all consent methods:
The message flow must provide the following information:
Please make sure that the message frequency disclosure, pricing disclosure, carrier disclaimer, opt-out and help instructions all match exactly the statements within your campaign's message flow. We will continue to refer to those statements as the "call-to-action" in the remainder of this document.
Please read the description of the documentation required for each of the consent options:
Online (website, mobile application)
When subscribers consent to joining your messaging campaign online, you need to provide the URL of the online form customers fill in.
If the online form is not publicly available (requires to login to an account, is behind a paywall), you must provide a screenshot or image of the entire form instead.
- A checkbox must be visible on the form, and needs to be ticked in to count as a valid consent
- The call-to-action must be visible and readable
Text-to-Join (also known as SMS opt-in)
When subscribers enroll to your campaign by sending a specific opt-in keyword, please make sure to list all the accepted opt-in keywords.
Note that allowing customers to re-join a campaign counts as an opt-in (e.g. "REJOIN", "RESTART")
When subscribers join your campaign verbally, you must provide the entire scripted conversation taking place between either an IVR system or an employee, and the subscriber.
- The script must include a confirmation of consent from the subscriber
- The script must include the call-to-action
Point of sale (including paper forms)
When subscribers fill in a paper form (such as a medical check-in form, employment or rental contract) or find the call-to-action on a flyer or any other physical support, you must provide an image, scan, PDF etc. of material which outlines the call-to-action to the subscribers.
For all other subscription methods, please provide a link to any relevant documentation outlining the call-to-action and ensuring subscriber's consent.
Terms & conditions
All the attributes of the SMS Terms must be in your Brand's T&Cs or in the Call-to-Action (CTA) & Message Flow. If the required attributes are supplied in the CTA and Message Flow, then all that is really necessary is that the brand has Terms & Conditions. It doesn't have to contain any SMS specific language.
In other words, this means that if the carrier disclaimer is added to the CTA and Message flow, then there are no sms T&C requirements outside of actually having a T&Cs doc.
Note: The carrier disclaimer must be "Carriers are not liable for delayed or undelivered messages".
It is now required that the sample messages of 10DLC campaigns include the opt-out instructions for each sample message.
The opt-out instructions are not required to be sent out in every outbound message in production, but the carriers want to see that the brands are making an effort to include it in their outbound messages. As a reminder, the best practice is to send the help and opt-out instructions at least once a month.
Example: “Geri’s Limo: Your next limousine has been booked and is on its way. Reply STOP to stop receiving notifications.”
Vonage will soon make some updates to its API to reflect those changes and allow customers to continue registering their campaigns without impact. In the meantime, please use the 'message_flow' attribute when submitting or updating campaigns.
Please reach out to your account manager or our support team if you need further details around those new requirements.