By now, many businesses are familiar with The Campaign Registry (or "TCR"). The Campaign Registry was created as a collaboration between major United States mobile telecommunications carriers to address the growing issue of consumers receiving unwanted text messages.
To be clear, The Campaign Registry is not operated by a federal authority. Rather it functions entirely as a collaboration between mobile carriers, virtual phone service providers ("service providers"), and businesses sending Application-to-Person ("A2P") SMS messages. As a result, the registration process continues to dramatically evolve, with some of the more daunting requirements implemented over the past few months. Understandably, many business owners have become frustrated with The Campaign Registry process.
History of The Campaign Registry
The Campaign Registry was created by major United States mobile carriers, including AT&T, T-Mobile, and Verizon, in 2020. However, major deadlines were not actually implemented until a few years later:
- March 31, 2023: the first significant registration deadline takes effect. Service providers accompanied the deadline with the threat of disruption to text message delivery services should businesses not comply;
- December 1, 2024: Businesses are informed that outbound text message traffic would be blocked for non-compliance.
- February 1, 2025: full enforcement of TCR requirements and penalty provisions. Non-compliant businesses would now have their outgoing text messages blocked, their services terminated, and receive stiff fines.
A Brief Overview of The Campaign Registry Compliance Process
As an initial matter, it is important to note that businesses do not actually register with The Campaign Registry themselves. Instead, they provide all relevant information to their service providers. Service providers will work with their clients to successfully register their 10-digit long code ("10DLC") virtual phone numbers on the TCR website.
Service providers will request a fair amount of information from their clients before beginning the TCR registration process on their behalf. Among other things, service providers will ask for information about the businesses (i.e., legal business names, business tax ID numbers, and website URLs) and their subject text message campaigns (i.e., the type of products or services provided by the businesses, how the businesses acquired consumer consent for the receipt of text messages, and estimated message frequency).
Why Should Your Business Obtain Assistance with TCR Registration?
The above is an abbreviated overview of the TCR registration process. Depending on the number of campaign registrations and their respective complexity, the entire process can take months to complete. Yet, completing the process is crucial, as registering virtual telephone numbers on The Campaign Registry ensures that SMS messages are more likely to reach their target audiences.
The attorneys at Klein Moynihan Turco provide clients with TCR registration assistance and draft their requisite Privacy Policies and Terms of Service. Our attorneys also advise clients on all manner of regulatory compliance and defend Telephone Consumer Protection Act ("TCPA") class action lawsuits.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
