Last Updated: 7.26.22

A2P Regulations & Conduct Contents

About A2P Messaging

Carriers in the United States and Canada have a strict interpretation of A2P and consider all messaging that passes through Apeiron and it’s Providers (or other messaging application platforms) to be A2P.

Some examples of A2P messaging include:

  1. Customer Service - customer service agents answering questions, schedule appointments, provide service information or conduct a satisfaction survey
  2. Reminders, Notifications, Alerts - delivery updates, appointment reminders, weather alerts
  3. UCaaS (Unified Communications as a Service)
  4. Marketing, Promotional
  5. 2FA (Two-Factor Authentication)
  6. Anonymized Numbers (Proxy Services) - car service communications between driver and passenger, customer-to-shopper grocery service chatting

For these messages to reach U.S. mobile subscribers they must be part of an approved campaign and are subject to ongoing compliance and monitoring obligations. Please read all articles on this page to familiarize yourself with the Use Cases and Conduct.


Prohibited Use Cases

Within the mobile messaging space, some marketing campaigns or segments are considered problematic by the carriers due to a high volume of subscriber complaints and propensity to be associated with deceptive practices - in other words, “high risk” and therefore prohibited use cases.

As stated by the CTIA, “Message Senders should use reasonable efforts to prevent and combat unwanted or unlawful messaging traffic, including spam and unlawful spoofing. Specifically, Message Senders should take affirmative steps and employ tools that can monitor and prevent Unwanted Messages and content, including for example content that: (1) is unlawful, harmful, abusive, malicious, misleading, harassing, excessively violent, obscene/illicit, or defamatory; (2) deceives or intends to deceive (e.g., phishing messages intended to access private or confidential information); (3) invades privacy; (4) causes safety concerns; (5) incites harm, discrimination, or violence; (6) is intended to intimidate; (7) includes malware; (8) threatens Consumers; or (9) does not meet age-gating requirements. Message Senders should take steps to ensure that marketing content is not misleading and complies with the Federal Trade Commission’s (FTC) Truth-In-Advertising rules.”

The landscape of SPAM has changed and carriers are taking a zero-tolerance approach to traffic that exposes subscribers to shady companies who use texts to tempt end-users into taking certain opt-ins. From “wipe out debt” to job scams asking consumers to share personal information or hand over money, many of these SPAM texts are sent by fee-charging businesses that make unrealistic promises to help with consumers’ money worries and prey on people in debt.

The following use-cases have been deemed high-risk and will be blocked by carriers even when the program claims to support opt-in and opt-out mechanisms. That’s right - even if there is an opt-in and an opt-out, the use-case could still be problematic. In the case of affiliate marketing, for instance, the consumer can text “STOP,” but what exactly are they stopping? More often than not, they are opting out of a single number, but their own number has been shared to the subscriber lists of hundreds or thousands of numbers across multiple content providers. This is the primary reason why affiliate marketing is high-risk and blocked by carriers.

Ultimately, carriers reserve the right to reject programs at their discretion on all messaging routes including short codes, toll-free numbers and standard (local) numbers. Please note that as new SPAM campaigns are identified every day, the below list may change or evolve at any time.

  1. Lead/Commission Generation, Affiliate Marketing
  2. Third-Party Loan Forgiveness, Loan Matching, Loan/Debt Consolidation, Debt/Student Debt Relief
  3. High-Risk Financial Services*
  4. Finance/Investment Opportunities
  5. Tax Relief
  6. Credit Report Scoring, Credit Repair/Related Content
  7. Work From Home, “Get Rich Quick,” Third-Party Job Recruitment, “Secret Shopper”
  8. Phishing, Fraudulent/Deceptive/Misdirecting Links
  9. CBD/Marijuana Dispensary Promotions, Tobacco, Vape, Federally Illegal Drugs
  10. Promotions of Any Illegal Substances or Prescriptions
  11. Gambling
  12. Sweepstakes**
  13. Any content containing malware or non-secure app downloads

* Some examples of these problematic “High-Risk Financial Services” campaigns include but are not limited to payday loans, short-term loans, auto loans, mortgage loans, student loans, stock alerts, cryptocurrency.
** Prohibited on toll-free. Sweepstakes may be acceptable on 10DLC long code routes dependent on carrier codes of conduct.
*** Note that while SHAFT is technically a policy which applies to short codes, any content on any sender ID type found to be in violation of SHAFT may be subject to blocking by the carrier or by Apeiron.


Use Case Guidelines

Adult Content Use Cases

Adult content is highly regulated and may likely be subject to additional reviews or audits in excess of other use cases.
All adult content programs must include as part of any and all opt-in methods a substantial, robust age gate effective in verifying the age of a subscriber at point of opt-in and preventing minors from subscribing. Additionally, the following content remains prohibited for adult content messaging:

  1. Illegal sexual themes of any kind, simulated or real, including the exchange of illegal sexual imagery
  2. Prostitution/exchange of intimate acts for money
  3. Misrepresentation of adult content as family-friendly
  4. Adult substances, actual or implied, targeting minors

Charitable Donation Use Cases

Programs facilitating end-users’ donations to charitable causes and organizations are supported on some carrier networks. Mechanisms for supporting this may vary by carrier. Consult individual carrier codes of conduct for details about how donations are supported and requirements for donation campaigns.

Emergency Notifications Use Cases

While emergency notifications are supported on all number types, it is recommended that the campaign undergo certification as applicable per number type.

High-Risk Use Cases

High-risk use cases (typically marketing) may not be outright prohibited but run a high chance of getting blocked or resulting in carrier complaint. It is critical to set expectations that the following use cases are unlikely to run smoothly on carrier networks.

  1. Mailbox Rental
  2. Cart Abandonment Notifications (read more below)
  3. Weight Loss
  4. Cart Abandonment Notifications

Cart Abandonment Notifications are sent as strategic marketing follow-ups to users who have added items to online shopping carts but did not complete their transaction. This is high-risk traffic because end-users did not directly opt in to receive text messages and these messages carry high potential for negative interaction with recipients.

Simply put - you must establish clear consent from recipients at the time information is collected. They must consent to the type of message and from whom they are receiving it. Carriers field a lot of subscriber complaints from marketing messages because e-comm businesses fail to get explicit consent from consumers. The Call-to-Action for opt-in should describe the types of messages recipients can expect to receive and should include clear opt-out instructions.

Therefore, there is always a high chance that carriers will block Cart Abandonment traffic and we advise against supporting this use case.

Higher Education & K-12 Use Cases

These messages are intended for teacher-parent-student communications and may not be used for marketing.

Machine to Machine Use Cases

IoT/M2M messages are not expected to engage in direct customer interaction and use cases intending to incorporate both direct consumer communication and IoT/M2M messages must utilize separate dedicated codes for each.

Political Use Cases

Political campaigns are supported but must run on the correct channel and must adhere to all applicable CTIA guidelines, including the Messaging Principles and Best Practices and Political Campaign Messaging Document as well as all carrier codes of conduct and the Apeiron Acceptable Use Policy. All prohibited behavior outlined in these articles must be avoided and compliance responsibilities must be obeyed. Depending on the carrier, political campaigns may be required to register and undergo vetting for authenticity. Please see carrier code of conduct documents for explicit instructions for carrier vetting.

Additionally, keep in mind that political campaigns must always:

  1. Obtain express consent prior to sending a message. Opt-in lists are not permitted to be shared, bought or sold for any message types. Political use cases are not excepted.
  2. Inform recipients at opt-in who will be messaging them
  3. Inform recipients at opt-in how many messages they will receive
  4. Inform recipients at opt-in how often they will receive messages
  5. Store all consent records in case of audit or inquiry
  6. Honor all opt-out requests

Sweepstakes & Contest Use Cases

Programs which offer a chance to receive a prize must adhere to all applicable laws and should consult legal counsel prior to submitting sweepstakes or contest campaigns for 10DLC, Verified Sender or short code certifications.