Service and Country Specific Requirements Change Log

Below is a log of the material updates or modifications to the individual Service and Country Specific Requirements that have been made since July 2021. These updates or modifications are effective immediately, unless otherwise specified below. Twilio recommends that you fully review and understand the individual Service and Country Requirements that have been updated or modified.

February 27, 2024

Services Using or Incorporating Artificial Intelligence or Machine Learning Technology: Added a new section titled “Services Using or Incorporating Artificial Intelligence or Machine Learning Technology”. This new section links to these additional terms that you are required to accept if you opt into using or activating optional artificial intelligence or machine learning technology features or functionality that are available for some Services.

Advisory Services Requirements: Clarified the definition of Twilio IP to exclude Customer Documentation and Customer Materials. Also clarified that if you rely on the Advisory Services to provide your own products and services to your customers, Twilio has no obligation or liability to your customers, and you will make your customers aware of the same.

Twilio Messaging Policy: Clarified that you may not transmit text messages that are used for security testing, including simulated phishing and other activities that may resemble social engineering or similar attacks.

Twilio SendGrid Email Policy: Clarified that Twilio SendGrid Email may not be used to conduct security testing, including simulated phishing and other activities that may resemble social engineering or similar attacks.

Twilio Voice Services Policy: Clarified that if you are using Programmable Voice or Elastic SIP Trunking to place telemarketing or advertising voice calls, you must obtain the callee’s prior consent, as required by applicable laws, regulations, governmental orders, industry standards, or telecommunications providers’ requirements or guidance.

February 7, 2024

Third Party Services: If you use the WhatsApp Business Platform, the WhatsApp Business Solution Terms apply to you if you are not an independent software vendor, and the Meta Business Messaging Technology Provider Terms apply to you if you are an independent software vendor.

January 26, 2024

Verify: One-Time Password (OTP) Text Message Delivery: Added terms for Twilio Verify that cover Twilio’s discretion to deliver OTP text messages using Google’s Rich Communications Services channel or a traditional SMS channel. Clarified Google’s ability to retain personal data if Google’s Rich Communications Services channel is used.

October 17, 2023

Services in Private Beta: Added terms that are applicable to any products and services that are identified as alpha, beta, limited release, or developer preview and made available to you on an invitation basis in a non-public or private manner.

September 27, 2023

Verify Fraud Guard: Added terms regarding refund eligiblity and claim submission in cases where Verify Fraud Guard fails to identify and block SMS-related pumping fraud.

July 6, 2023

Australian Phone Numbers: Added the following regulatory requirements relating to Australian phone numbers:

  • Notification obligations if you are considered a carriage service provider under applicable law or regulation, and
  • If you are considered a carriage service provider under applicable law or regulation, (a) appointment of Twilio Inc. to act your Data Provider under the Integrated Public Number Database Industry Code C555:2020; (b) permitting Twilio Inc. to provide Public Number Customer Data to the Integrated Public Number Database under your Carriage Service Provider Code; and (c) clarifying your obligations regarding accuracy of Phone Number Customer Data and your responsibilities regarding any operational or technical matters in connection with Public Number Customer Data. 

June 26, 2023

Third Party Services: Added Spoke Phone, which is provided by Spoke Network Inc. or its affiliates and governed by the Spoke Phone Terms of Use, under the section titled "Third Party Services".

March 1, 2023

Twilio Identity Verification - Twilio Lookup API - SIM Swap and Line Type Intelligence, Lookup Call Forwarding, Identity Match, Phone Number Verification, & Call in Progress: Updated these terms to reflect that Twilio Inc. or one of its affiliates will provide the Identity Verification Services instead of Boku Identity, Inc., which is an affiliate of Twilio Inc.

February 14, 2023

Service and Country Specific Requirements: Clarified that this log is deemed as reasonable and sufficient notice to you of any material updates or modifications to any Service Specific Requirements, Country Specific Requirements, or Country Specific Requirements for Communications Services ("Requirements"). Your continued use of Twilio's products and services that are subject to any Requirements constitutes your acceptance of the updated or modified version of the applicable Requirements. Twilio recommends that you periodically review this change log to be aware of any material updates or modifications.

Advisory Services Requirements: Update the Advisory Services definition to include configuration, expert, or implementation services. Updated the Advisory Services Package definition to include the packages available at https://twil.io/professional-services/offerings. Added a definition for Subcontractors, which are treated similarly to Twilio Personnel. Clarified the Twilio IP definition by including technical configuration, workflow templates, starter code, and software components. The perpetual license you had to use Twilio IP has been updated such that you have the right to use Twilio IP that is start code or software components in accordance with the applicable open-source license.

Twilio Segment Customer Data Platform: Updated these terms to incorporate latest support plans and terms for Twilio Segment's Customer Data Platform (CDP).

Twilio SendGrid Email Policy: Updated these terms to clarify and add more specificity around affirmative consent and revocation of affirmative consent requirements, prohibited content and actions, and email deliverability and Twilio SendGrid Email Services performance risks. Added new obligations regarding preventing unauthorized access to your account and the Twilio SendGrid Email Services and removing that access for your end users and customers that violate the Email Policy.

January 1, 2023

Twilio Segment Customer Data Platform: Updated these terms to reflect that Twilio Inc. or one of its affiliates will provide the Segment Services instead of Segment.io, Inc., which has been merged into Twilio Inc.

Third Party Services: Moved terms relating to Marketplace Add-ons provided to you by third party partners under the section titled "Third Party Services".

December 6, 2022

Advisory Services Requirements: Clarified the Advisory Services do not constitute legal or compliance advice or guidance and that you are responsible for your reliance on the Advisory Services, including any documentation Twilio creates for you.

Third Party Services: Moved terms relating to Marketplace Add-ons provided by third party partners under the section titled "Third Party Services".

November 10, 2022

Electric Imp: Added that a third party provider's terms apply to the use of any pre-provisioned third party products or services with Electric Imp. Included an explicit disclaimer that Twilio is not responsible for any hardware manufactured by a third party that you use with Electric Imp.

November 4, 2022

Third Party Services: Added Patient Assist, which is provided by SpinSci Technologies, LLC and governed by the SpinSci EULA Software License Agreement, under the section titled "Third Party Services".

October 6, 2022

Third Party Services: Added a section titled "Third Party Services", which covers third party terms that apply if you use any third party products and services that Twilio is reselling.

September 15, 2022

Advisory Services Requirements: Clarified that these terms only apply if the Advisory Services being provided are not governed by the Advisory Services Terms. Added terms that specifically apply to Advisory Services that are educational courses.

Twilio Segment Customer Data Platform: Updated these terms to clarify that any patient, medical, or other health information is not prohibited so long as you ensure that you have the necessary protections and agreements in place with Twilio that are required by law or regulation in order for Twilio to process that patient, medical, or health information.

August 3, 2022

Twilio Identity Verification - Twilio Lookup API - SIM Swap and Line Type Intelligence, Lookup Call Forwarding, Verify Silent Network Auth, Identity Match, Phone Number Verification, & Call in Progress: Verify Silent Network Auth is now covered under these Twilio Identity Verification terms.

July 14, 2022

Twilio Identity Verification - Twilio Lookup API - SIM Swap and Line Type Intelligence, Lookup Call Forwarding, Identity Match, Phone Number Verification, & Call in Progress: Added new terms covering the restrictions, requirements, and security controls for Twilio and Boku Identity Verification products, specifically Twilio Lookup API - SIM Swap and Line Type Intelligence, Lookup Call Forwarding, Identity Match, Phone Number Verification, & Call in Progress.

April 4, 2022

Twilio Voice Services Policy: Programmable Voice & Elastic SIP Trunking: Added a new policy, covering the restrictions and requirements specifically for Programmable Voice and Elastic SIP Trunking, such as voice call duration requirements, prohibited activities, and requirements for telemarketing and advertising voice calls.

Twilio Segment Customer Data Platform: Updated these terms to make them clearer, more streamlined, and comprehensively cover the restrictions and requirements for using Twilio Segment's Customer Data Platform (CDP).

Advisory Services Requirements: Made minor clarification changes, including to the definition of Advisory Services and Twilio IP and the services that are out of scope.

March 14, 2022

Twilio Messaging Policy: Messaging - SMS, MMS, Chat, & WhatsApp: Updated the Twilio Messaging Policy to cover that Twilio proactively identifies and does not accept text messages in violation of the Twilio Acceptable Use Policy.

March 2, 2022

Text Message Content Collection and Monitoring for United States & Canadian Numbers: Added terms that Twilio proactively identifies and does not accept text messages in violation of the Twilio Acceptable Use Policy.

February 1, 2022

Advisory Services Requirements: Replaced the definition for SOW with a definition for Order Form, which covers both statements of work and ordering documents.

December 15, 2021

Twilio Flex: Clarified that Proxy is included as a Standard Product.

August 2, 2021

Twilio SendGrid Email Policy: Added a new policy, covering the restrictions and requirements specifically for Twilio SendGrid Email, such as consent and age gating requirements and prohibited content and actions.


May 31, 2022

Australian Phone Numbers: Added regulatory requirements, covering that information relating to Australian phone numbers that are reassigned to a carriage service provider must be true, complete, and accurate. This includes the name and contact information of the carriage service provider to which an Australian phone number is assigned.

September 28, 2021

Illegal Robocalling Obligations for Voice Calls to/from United States Phone Numbers: Added regulatory requirements, obligating domestic and foreign voice service providers to register with the Federal Communications Commission's Robocalling Mitigation Database. Failure to register will result in Twilio blocking or otherwise not transmitting voice calls.

October 8, 2021

Emergency Services (Japan): Added regulatory requirements, prohibiting the use of the Services to contact emergency services in Japan and using Japanese phone numbers for call forwarding purposes if an alternative method of contacting emergency services is not in place.