What type of consent is required for 2FA or OTP message programs on TFN?

[Meredith_W]

2-factor authentication (2FA) or one-time passcodes (OTP) are common use cases for toll-free messaging.

Although the type of consent may vary, all business messaging use cases – including 2FA/OTP messaging – requires consent from the end user to send messages. For 2FA/OTP messages, you must have express consent to send a 2FA or OTP text message. Typically, express consent for a 2FA/OTP text message is obtained by informing the user they will receive a 2FA/OTP notification at the phone number they provide, or informing them when they update their phone number in an online profile.

To get your toll-free number verified for a 2FA/OTP use case, you must provide proof of consent. A screenshot or live URL is ideal. If you don't have a screenshot or URL available, then you must provide a thorough, detailed description of how you collect the end user's express consent. 2FA/OTP use cases do not exclude the need to provide proof of consent, and language in T&Cs or Privacy Policy is not sufficient for express consent. 

If you need more info on messaging best practices when it comes to consent, please refer to the 

 CTIA Messaging Principles and Best Practices.

[#2]

Unverified TFNs and Pending Verification TFNs are subject to industry-wide messaging limits or blocking. Unverified TFNs are toll-free numbers that have not completed the toll-free sender verification process. Pending Verification TFNs are toll-free numbers where a verification request has been submitted, but the request is pending review and approval.

UPDATE: As a result of industry-wide changes, all messages from Unverified Toll-Free numbers will be blocked, effective November 8, 2023. On this date, all Unverified Toll-Free numbers will require a pending verification request or to be in a verified state in order to originate traffic. All messages from Pending Toll-Free numbers will be blocked, effective January 31, 2024. On this date, all Toll-Free numbers, regardless of the use case, must be verified to originate traffic.

UNVERIFIED Toll-Free numbers (TFNs) are subject to industry-wide blocking, effective November 8, 2023.

PENDING VERIFICATION Toll-Free numbers (TFNs) are subject to industry-wide U.S. messaging limits per TFN*:

• Daily Limit: 2,000 messages per day per pending TFN 
• Weekly Limit: 6,000 messages per week per pending TFN 
• Monthly Limit: 10,000 messages per month per pending TFN 

*Pending verification TFN traffic will be blocked beginning January 31, 2024.

Unverified TFNs will be blocked with  Sinch error code 64 “Blocked due to exceeded quota”. Pending Verification TFNs that exceed messaging limits will be blocked with Sinch error code 64 “Blocked due to exceeded quota”. Please see Toll-Free Delivery Report Errors for a full list of Sinch Toll-Free error codes. 

Pending Verification TFNs are subject to more stringent message filtering than Verified TFNs. Beginning January 31, 2024, all traffic originating from pending verification TFNs will be blocked.