# 30475: Toll Free verification rejection - Opt-in not sufficient: Cannot combine consent for messaging with requirement for service

Log Type: APPLICATION

Log Level: ERROR

## Description

The Toll-Free phone number verification submission has been reviewed and it was rejected. Effective Jan 31st, 2024, messaging traffic on this Toll-Free number is blocked until it's verified.

Verification is one component of ensuring A2P SMS is used by businesses in a legal and compliant manner. The review process looks at the business sending messaging (not the software powering it), the use case, sample content, the web presence, the opt-in/consent collected and associated website terms and privacy policies.

### Possible causes

Your opt-in mechanism requires that the consumer opt-in to messaging as a requirement of using your service, which is not allowed.

Consent cannot be a requirement for your business's service. A business may not combine collecting a consumer's phone number with opting-in to receive marketing messaging. An explicit opt-in leaves no ambiguity for why the customer gave the phone number, and for how they expect the company will communicate with them.

Opt-in refers to the process of getting a consumer's permission to send them text messages. According to TCPA law, businesses must have "express written consent" from the consumer before texting them. NonConsumer (A2P) Message Senders should:

* Obtain a Consumer's consent to receive messages generally;
* Obtain a Consumer's express written consent to specifically receive marketing messages; and
* Ensure that Consumers have the ability to revoke consent.

Note: If there is promotional messaging on this toll-free phone number, it requires express written consent.

### Possible solutions

* Ensure your opt-in mechanism is a distinct action during a consumer's sign up for your service.
* An opt-in call-to-action (CTA) with a checkbox must be unchecked by default.

Resources:

[CTIA guidelines](https://www.ctia.org/the-wireless-industry/industry-commitments/messaging-interoperability-sms-mms)

[Consent/Opt-In](https://www.twilio.com/en-us/legal/messaging-policy#:~:text=with%20Twilio%20policies.-,Consent%20/%20Opt%2Din,-What%20Is%20Proper) in [Twilio's Messaging Policy](https://www.twilio.com/en-us/legal/messaging-policy)

[Why was my Toll Free Verification Rejected?](https://support.twilio.com/hc/en-us/articles/9321443984155-Why-Was-My-Toll-Free-Verification-Rejected)

[Required information for Toll-free verification](https://support.twilio.com/hc/en-us/articles/13264118705051-Required-Information-for-Toll-Free-Verification)

[Toll-Free best practices](https://support.twilio.com/hc/en-us/articles/360038172934-Information-and-best-practices-for-using-Toll-Free-SMS-and-MMS-in-the-US-and-Canada)