New requirements for Toll-Free A2P Messaging
To ensure greater accountability and message legitimacy in Toll-Free Application-to-Person (A2P) messaging, new verification requirements are being introduced. The fields detailed below will be available beginning October 1, 2025 and will become required February 17, 2026. Please ensure you are collecting this information from your customers as they onboard so you are prepared for this change.
For US-based businesses
You will need to provide your Employer Identification Number (EIN) as your Business Registration Number (BRN).
Sole Proprietors/Businesses without an EIN: If you do not have an EIN issued by the IRS, please indicate "Sole Proprietor" as your Entity Type on your submission. This will initiate a manual exemption process, though approval is not guaranteed and may extend processing time. Sole Proprietors will only be supported for US based businesses.
For businesses located outside of the US
You must supply your official business registration number issued by your local or national business authority. While required documents vary by country, ensure you can provide a document showing:
Your legal business name
A valid business registration number
The name of the issuing authority (e.g., Companies House in the UK, Corporations Canada)
New fields for Toll-Free Verification submissions
Three new fields will be added to the Toll-Free Verification submission form:
Business Registration Number: Your official BRN.
Business Registration Type: Examples include EIN, Canada Revenue Agency (CRA), or Companies House.
Business Registration Country: The ISO 3166-1 Alpha-2 country code (e.g., US for the United States, CA for Canada).
For more information about other countries’ Alpha-2 codes, please visit the ISO Online Browsing Platform, select Country codes, and click Search.
Frequently Asked Questions (FAQs)
Will brand verification impact timelines for verification?
There is no expected change to the timelines for verification.
Can sole proprietors still register for toll free messaging?
Sole proprietor submissions will only be accepted for US-based businesses. As with 10DLC, sole proprietor eligibility is determined if an entity has an EIN, not designated by your entity type identified by the IRS.
Beginning October 1, 2025, you may submit sole proprietor brands using the new fields to test the flow and any timeline impacts. The introduction of these fields should not extend the current verification timelines.
Can I provide different identification than an EIN?
EINs are the required identification for US brands, unless they are eligible as a sole proprietor. In Canada, a Canadian Business Number (BN) should be provided. Support for Canadian Provincial Numbers and VAT Numbers will be included prior to the BRN field being required on February 17, 2026.
Canadian Toll-Free customers without a BN should continue registering without the optional fields until Provincial Numbers are supported. At this time, sole prop will not be supported for Canadian businesses.
Will the BRN need to match the website/opt-in form/email domain? Or can there be a separate, DBA name section that connects to those fields?
The BRN must match the legal entity name and DBA will continue to be an optional field. Brand contact details must align with the legal entity name or DBA.
Is this a Bandwidth requirement?
This is an industry wide requirement from our Toll-Free partner.
How will I know if my submission has been denied due to brand verification? How can I appeal?
If your submission is denied due to brand verification, you will receive denial code 1112 - Business Registration Number Is Missing or Invalid. If you receive this code, please note that the remainder of the brief has not been reviewed for compliance
The appeal process will be communicated at a future date.
Will the “entity type” field replace the “use case” field?
“Entity type” is a new field, distinct from “use case” field. Both fields will need to be provided, similar to 10DLC.
What should I do for my submissions during the optional period?
In this period, submissions will still undergo vetting but will not be rejected based on lack of BRN. However, if the BRN and associated fields are provided, it will be evaluated for compliance. Meaning, if the data provided cannot be verified or is non-compliant, the registration will be rejected. Also keep in mind that all three fields (business registration number, business registration type, business entity type) must be provided if you elect to provide this information during the optional period.
Will existing TFNs need to go back through verification to add the BRN?
No, at this time, only net-new verifications will need to include the BRN.