New US Short Code Certification

For a short code to be certified, all required campaign components must meet carrier expectations. Remember: being legally compliant to the TCPA does not satisfy carrier requirements. Carriers can and will refuse to certify campaigns which uphold TCPA but do not meet their individual requirements.

Short Code Self-Check

Carriers conduct routine audits on all components of a live short-code program to ensure ongoing compliance, but this begins during the program certification process, so it is important to not only get off to a good start but sustain compliance at all times.

Ask yourself the following questions when reviewing your mobile program. If you answer “no” to any of them, your campaign is at risk of noncompliance.

• Have you completed brand vetting through the Short Code Registry, or has Convey completed it on your behalf?
• Do all of your CTAs display opt-in instructions, a brief description of service, the word “recurring” if applicable, a message and data disclaimer and links to both Privacy Policy and mobile program Terms & Conditions clearly and conspicuously?
• Is the “who, what, when, where, how” about your campaign obvious in your CTA?
• Are all of your mobile programs clearly identified?
• Have all of your mobile end-users provided express consent as defined by both the CTIA and the FCC TCPA?
• Does your users’ consent apply solely to the program(s) for which they have expressly opted in?
• Are your HELP and STOP keywords functioning properly, regardless of whether the end-user is opted into the program?
• Do you present HELP and STOP information at point of opt-in?
• Do you fulfill all opt-out requests within 72 hours of the end-user texting “STOP”?

Certification Process and Timeline

Short code certification is an extensive process, which can require a lot of back-and-forth between Convey, customers and carriers as programs are brought up to compliance standards. 

Prior to leasing a short code, the viability of the use case is assessed per a short code program brief. Once assessment is completed and a code is leased, the program is reviewed for compliance readiness before it is submitted to the carriers. Once submitted to the carriers, the estimated timeline is an additional eight to twelve weeks, however, carriers may request additional changes. Once carriers complete review, keywords are tested for program alignment and provisioning is completed. Once all carriers have approved, the code may begin sending live traffic.

Certification Documentation

A program brief is required for all new programs and amendments. This brief includes information such as:

• Program name
• Opt-In process/Call-to-Action (includes adequate description of use case, the brand name, message frequency, data rates disclosure, help instructions, opt-out instructions, link to the Privacy Policy and short code Terms and Conditions.)
• Opt-In confirmation MT (contains brand name, a message frequency disclosure, data rates disclosure, help instructions, and opt-out language.)
• STOP/Opt-Out MT (contains brand name, confirms opt-out, and states no further messages will be sent.)
• HELP MT (contains brand name and customer care contact information (email, phone number, support website))
• Example MT
• Brand customer care info (an Email, Toll-Free number, and Website URL)
• Mobile Terms and Conditions URL (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. See the Terms and Conditions Requirements Article.)
• Privacy Policy URL (This may be the brand's general Privacy Policy)

Short codes may be ordered and leased through Convey. If you wish to lease a short code directly through the Short Code Registry, the most up-to-date receipt must be provided for certification.

Adding MMS Support to a Short Code

Short codes must be certified for MMS independently from their SMS certification, even if the same short code will be used for both services and has already been certified for SMS.

It is Convey’s policy to submit new certifications for SMS and MMS concurrently, as when submitted simultaneously the MMS certification comes at no additional charge, while submitting MMS later on will incur a full amendment fee. For more information about the cost of MMS certification, speak with your Convey Account Manager.

In order to certify for MMS via short code we must exemplify the MMS use-case - in other words, how will MMS be used to engage with the end-user on this code? As such, we will need some things from you:

1. A summary of how you intend to use MMS on the code.
2. One or more example outbound messages (including images).