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Why is VoIP SMS for person-to-person-10DLC so annoying?

· 4 min read
David
Chief Ranter in Chief

What the heck is 10DLC and why do I care?

Recently a friend of mine who works at a church asked a question, and I provided some details that qualifies as a rant:

Does anyone have a cheat sheet for the 10DLC rules that I can give to leadership. There's a lack of understanding why I'm deploying SMS is a challenge. In their mind everyone texts all the time, so it's no big deal.

Quick aside: 10DLC stands for 10-Digit Long Code. It's how electronically sending SMS is referred to from full 10-digit phone numbers, versus the SMS short codes that are 5- or 6-digit numbers you've likely received text messages from before (these have their own rules already and generally cost thousands of dollars per month to control and use).

Anyway, there are a number of other resources out there for more 10DLC info; Telnyx has this one for example about 10DLC Campaign Compliance. The important parts are: fines are insanely expensive, and there's zero concept in the rules for person-to-person communication outside of a cellular phone—every rule assumes you're sending bulk messages via an API/application whether you intend to or not. So sending one-on-one messages must still go through the same vetting and rules as someone sending a low-volume 10DLC campaign, meaning 3.75 messages per second and up to 6,000 messages per day sent. And registering costs up-front to get verified as a brand, and ongoing fees for each "campaign" you send, that each phone number must be associated with. It's likely carriers will eventually just outright block SMS messages that aren't registered with 10DLC.

Lets add a couple of other links for reference if you want more context:
https://help.twilio.com/articles/4407882914971-Comparison-between-Sole-Proprietor-Low-Volume-Standard-and-Standard-registration-for-A2P-10DLC

That article is linked from:
https://www.twilio.com/docs/messaging/compliance/a2p-10dlc/direct-standard-onboarding

So the gist is, the cellular carriers don't have a concept of person-to-person texting outside of a physical cell phone, and otherwise they assume you're a spammer and require registration with heavy authentication requirements of you as a business entity (with up front and ongoing fees through your provider--some providers eat these depending on their pricing, but they are either paying them or passing them through) so that when you do send spam SMS, they can 100% identify you and shut you down, and if you send spam without registering, you can be heavily fined for doing so (or your carrier that enabled you to do so will be fined and they're going to pass it along to you, or more likely not let you access SMS without being compliant so they don't have to, and so you agree to be responsible).

The reason foe this is that SMS spam got super bad, and the FCC was going to make the carriers fix it with regulation like the STIR/SHAKEN rules they're forcing compliance with (slowly) to cut down on spam robocalls and make Caller ID names more trustworthy. The carriers saw the writing on the wall and decided to "self-regulate" in a way that would let them both charge fees and enforce their own rules rather than the government forcing less favorable rules on them if they did nothing.

So you get the bucket of suck that only large bureaucracies can come up with by committee to cement their own control and revenue while avoiding the big bad (to them) government bureaucracy from being forced on them. And if they can accidentally ignore person-to-person texting existing outside of their actual cell phones and no one big enough complains, they can keep that monopoly for themselves (plenty of companies are using low-volume 10DLC campaigns for person-to-person texting anyway, but it's not an explicit reason you can provide for the campaigns when you register).