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Short Code Call-to-Action (CTA)

Updated

A Call-to-Action both describes a mobile program and provides opt-in instructions to potential users. Remember: the carriers’ goal is to promote a consistent end-user experience across all short-code programs, so although some compliance language may differ depending on the type of media the CTA is published in, certain aspects remain expected across all mediums:

  • Company name
  • Program name
  • Description of offer
  • Short Code Terms & Conditions’ location*
  • Privacy Policy location
  • Customer support (HELP) information
  • Opt-in Instructions
  • Opt-out Instructions (if recurring. Not required for OTP/2FA use cases)
  • Message & data rates disclaimer
  • Message frequency statement (if recurring. Not required for OTP/2FA use cases)

* The Terms & Conditions referenced here are not general company T&Cs, but rather T&Cs specific to short code and have unique requirements to meet compliance standards. 

NOTE: All of the above should be located before/above the submit button or signature line, including the links to Terms and Privacy Policy. Links to Terms and Privacy Policy located in the page’s footer or anywhere below the submit do not meet compliance standards.

The “Why” About CTA Requirements

What the CTA provides is an answer to five “Ws” - who, what, when, where, how - to do with your mobile program. Below, we answer your “why” with in-depth explanations of which questions each compliance component answers.

Question Component Reason
Who Company Name Any mention of the sponsor company name in the CTA must be consistent. If the CTA mentions “ABC University” in one sentence and “ABCU” in another, this a conflict in company name consistency which will be flagged by the carriers for its potential to cause end-user confusion. Ensure that your sponsor name remains consistent throughout your CTA, even if it seems repetitive.
What Program Name
Program Description 		Just as with the company name, the name by which you refer to your program must be consistent throughout your Call to Action. Furthermore, the words describing what your service provides must be clear and conspicuous without hidden meaning.
Where T&Cs Location
Privacy Policy Location 		Users should be provided instructions for accessing your mobile program T&Cs and company privacy policy within your CTA, to answer any questions they may have about opting into your program that aren’t answered in the CTA itself.
When Duration
Frequency/Recurrence 		Is your program on-going indefinitely or is it a one-month-long promotion? These questions must be answered in your CTA. Furthermore, while outright message frequencies expressing a detailed number of messages per time period are no longer required, programs that are subscription-based - or “recurring” - must state that fact within their CTA.
How Opt-in Instructions
Message&Data Disclaimer 		“Text PROMO to 54321” is an example of an opt-in instruction. “Message and data rates may apply” is the standard-rate service’s pricing information. All of these things should be clear on your CTA and should not require scrolling or page-turning away from other portions of the CTA to read.*

*Note: Never use the word “FREE” for a standard campaign. Subscribers are still paying for message and data rates via their carrier.

CTA Best Practices

Implementing these CTA best practices are important steps to getting your SMS campaigns approved at the Registries.

  • Clear and Conspicuous: ‘Consent language’ is what the user is agreeing to receive. There must be clear, conspicuous disclosure of the messages the user will receive. Example: “By entering my number, I am agreeing to receive text messages related to billing notifications…”.
  • Proximity: The consent language to which user is agreeing to receive texts needs to be clearly visible and in close proximity to the call to action where they enter their number. You can’t bury the consent language where it is hard to see such as small print at the bottom of your page, or behind a link that the user must click through to see.
  • Brand Identity: The business must be clearly identified by either its company name or registered d/b/a.
  • Opt-in Checkbox: End-users must be capable of submitting a form for services without opting into text messages by default. A good practice is to include a specific checkbox for SMS opt-in. Note: It cannot be pre-checked.
  • Privacy Policy: Include a link to the brand’s privacy policy so consumer understands how their information will be used. If it is shared or sold to 3rd parties for other purposes, etc, carriers have the right to not accept the Campaign.

Example CTA

The following is an example of a live CTA:

Text SMS to 77039 for recurring mobile marketing tips from Aerialink Messenger. Msg&DataRatesMayApply. Reply HELP for help, STOP to cancel.
Privacy Policy: https://www.aerialink.com/legal/privacy-policy/
Mobile Terms & Conditions: https://www.aerialink.com/legal/short-code/77039-sc/

Please keep in mind that on a web page, the T&Cs and Privacy Policy may take the form of linked text, but in print CTAs the full URL must be explicitly shown as demonstrated above.

Web Form CTAs

Web form CTAs have the same requirements as other types, but here are some additional factors to keep in mind:

  • The “phone” field cannot be mandatory.
  • The SMS Checkbox cannot be pre-checked, and cannot have agreement to SMS as a condition of moving forward in the form.
  • All compliance language - including links to Terms & Privacy - must be located above the “submit” button.

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