30446: Toll Free verification rejection - Opt-in not sufficient: express consent required
The Toll-Free phone number verification submission has been reviewed and it was rejected.Effective Jan 31st, 2024, messaging traffic on this Toll-Free number is blocked until it's verified.
Verification is one component of ensuring A2P SMS is used by businesses in a legal and compliant manner. The review process looks at the business sending messaging (not the software powering it), the use case, sample content, the web presence, the opt-in/consent collected and associated website terms and privacy policies.
The Opt-in workflow provided in the toll-free verification is not sufficient. Express Consent is required. Express Consent is more than collecting a phone number - it is a voluntary, informed end user choice for a specific purpose - it requires upfront disclosure and intentional action. Explicit opt-in leaves no ambiguity for why the customer gave the phone number, and for how they expect the company will communicate with them. Every end business must have consent from each recipient they send a message to. Consumers may give permission over text, on a form, on a website, or verbally. Consumers may also give written permission. Listing "SMS" in your Terms of Service or Privacy Policy is not Express Consent.
Note: If there is promotional messaging on this toll-free phone number, it requires express written consent.
Opt-in refers to the process of getting a consumer's permission to send them text messages. According to TCPA law, businesses must have "express written consent" from the consumer before texting them. NonConsumer (A2P) Message Senders should:
- Obtain a Consumer's consent to receive messages generally;
- Obtain a Consumer's express written consent to specifically receive marketing messages;
- Ensure that Consumers have the ability to revoke consent
- Correct your opt-in process to collect a consumer's express consent via CTIA guidelines and resubmit the toll free verification
- Note: An opt-in call-to-action (CTA) with a checkbox must be unchecked by default
Why was my Toll Free Verification Rejected?