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T-Mobile Code of Conduct - Three major differences from the CTIA guidelines you should know about

Nicole Culver

Nicole Culver

January 7, 2021

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T-Mobile published an update to their Code of Conduct as it relates to Commercial (aka business) Messaging on November 1st, 2020 and if you aren't paying attention, you should be. This document details T-Mobile's preferences and requirements for business messaging traffic on their network, which your business will need to adhere to if you intend to reach anyone with a T-Mobile-connected device via text message.

You might be wondering, Wait, what about the CTIA guidelines? Well, this post is all about what T-Mobile's Code of Conduct means alongside the CTIA's messaging guidelines, including how they differ and what's basically the same between the two. The important thing to note here is that the CTIA's Messaging Principles and Best Practices are industry guidelines designed to help inform carriers like T-Mobile and message senders, like your business, on what the best practices are for sending business messages. T-Mobile's Code of Conduct is their declaration of rules pertaining to their network, which means that any consumer with a T-Mobile device is effectively gated by these requirements.

First, let's review

The CTIA, a telecom industry organization, is a group of representatives from major telecom companies such as wireless carriers, VoIP operators, and CPaaS companies like Bandwidth. Straight from the source, the 'CTIA represents the U.S. wireless communications industry.' Part of the CTIA's mission is to 'Convene the industry to tackle our most difficult challenges and coordinate voluntary best practices and initiatives.' Together, the CTIA agrees on best practices that set the tone and expected behavior throughout the communications industry. The group meets regularly, but releasing updates only occur once every few years, most recently being the July 2019 release of theMessaging Principles and Best Practices.

That document is what has influenced the practices and policies of carriers like AT&T and T-Mobile when it comes to how they filter business messaging traffic. The CTIA is not a governing body or controlled by one, like the FCC for example, meaning that they can only suggest-not enforce-these guidelines. So, where does the real enforcement actually happen? Well, broadly, it doesn't. Each carrier is responsible for setting their own policies, and they don't have to agree, making the landscape very complicated.

What does that really mean?

Let's walk through an example. As mentioned in the last post in this blog series, AT&T has decided to block public URL shorteners entirely, but T-Mobile only suggests that they may get blocked. If your business decides to send a text message to your subscribers that contains one of these links (i.e., Bitly, TinyURL, Hyperlink), that message will definitely not make it to the AT&T mobile user and it only might make it to the T-Mobile user. Because of this inconsistency, it's better to just take the safe road and not use these free public URL shorteners. Otherwise you risk your messages not getting delivered, and, I cannot remind you enough, you pay for every message you send, not just the ones that are delivered.

Back to the comparison

If you look at the CTIA guidelines and T-Mobile's Code of Conduct side by side, you might think, Wow, these are really similar so what gives? Well, these guidelines are meant to help guide the carriers' policies so the similarities are a good thing. The types of messages and related opt-in requirements, for example, are the same:

Conversational messaging	Informational messaging	Promotional messaging
Conversational messaging is a back-and-forth conversation that takes place over text. If the consumer texts into the business first and the business responds quickly with a single message, it's likely conversational. If the consumer initiates the conversation and the business simply responds, no additional permission is required.	Informational messaging is when a consumer gives a business their number and asks to be contacted in the future. Appointment reminders, welcome texts, and alerts fall in this category because the first text sent by the business fulfills the consumer's request. A consumer should agree to receive texts when they give the business their mobile number.	Promotional messaging is when a message contains a sales or marketing promotion. Adding a call-to-action like a coupon code to an informational text may place it in the promotional category. Before a business sends promotional messages, the consumer must agree in writing to receive promotional texts. Businesses that already ask consumers to sign forms or submit contact information can add a field to capture consent.
- The first message always sent by the consumer - Two-way conversation - Message responds to a specific request	- The first message is sent by the consumer or business - One-way alert or two-way conversation - Message contains information	- The first message is sent by the business - One-way alert - Message promotes a brand or product - Prompts consumer to buy something or go somewhere
IMPLIED CONSENT If the consumer initiates the text message exchange and the business only responds to each consumer with relevant information, no verbal or written permission is required.	EXPRESSED CONSENT The consumer should grant permission before the business texts them. They can grant permission over text, on a form or website, or verbally. Written permission also works.	EXPRESSED WRITTEN CONSENT The consumer should give written permission before a business text them. They can sign a form or check a box to allow promotional text messages. Participation intext promotions should never be a requirement.

What's noticeably different in T-Mobile's Code of Conduct is that there are more detailed requirements than the initial guidelines provided by the CTIA. The three most important differences between the two documents are listed below:

1. T-Mobile has defined an actual cadence for opt-out notifications. 'Reply STOP to unsubscribe' should be included 'on the first message and at least every 5th message or at least once a month for continued consumer awareness.'
2. A 'high' volume or percentage of opt-out messages is considered to be 'greater than 4% opt-out within 24 hours' and if a single campaign blast exceeds 0.5% opt-out, that campaign blast should be flagged and audited. These are not generous numbers.
3. Snowshoe sending, or the practice of 'spread[ing] messages across many source phone numbers to dilute reputation metrics and evade filters', is strictly prohibited by T-Mobile. They have declared that they are 'actively monitoring' for this kind of sending and can disable these campaigns as a result.

Ultimately, T-Mobile is drawing a line in the sand around what they will and will not abide by on their network, making the CTIA guidelines into actionable requirements for the carrier. While this is extremely practical for T-Mobile in a vacuum, your business is not only messaging T-mobile end users. In a perfect world, the carriers would come together and agree on a single set of requirements, but that doesn't seem likely in the near term.

In the meantime, Bandwidth is here to help.

Have questions?

If you're concerned about your message deliverability or have questions about the industry best practices and want to learn more, feel free to check out our resources or ask to talk to an expert. Navigating the messaging landscape is complicated, but you don't have to do it alone.

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