Text-to-win campaigns and SMS-based promotions have long been a powerful tool for consumer engagement. But as mobile marketing evolves, so do the compliance requirements bringing a major shift in regulations.
The Cellular Telecommunications and Internet Association (CTIA) is rolling out stricter regulations that affect how brands use short codes and 10-digit long codes (10DLCs) to communicate with consumers. If your brand runs SMS campaigns or sweepstakes, these changes will directly impact how you plan, launch, and manage mobile experiences.
Here’s what you need to know to stay compliant and competitive.
The End of Shared Short Codes
One of the most impactful changes is the discontinuation of shared short codes. Previously, multiple brands could share a single 5 or 6 digit SMS short code for “text to win” campaigns. This is no longer allowed.
Going forward:
- Each company must register its own dedicated short code.
- Registration must include the company’s EIN, specific use case descriptions, and pass carrier-level brand vetting.
- The same level of scrutiny is expected to extend to 10DLC numbers soon as well.
Terms, Privacy, and Transparency Are Now Mandatory
Carriers and the CTIA are demanding a new level of transparency. All SMS campaigns must now include:
- SMS Terms & Conditions outlining what data is collected, how it’s used, and opt-out procedures.
- A Privacy Policy that explicitly states that personal data collected via SMS will not be sold or shared without consent.
- Links to both documents in all outgoing campaign messages.
- For regulated verticals like alcohol, brands are required to implement robust and defensible age-gating measures that go beyond simple yes/no questions and clearly demonstrate how underage users are blocked. Use case descriptions for age-restricted products should clearly document age verification safeguards.
Opt-In and Opt-Out Consistency Across Platforms
Consumer consent is now under a microscope. The CTIA requires:
- Immediate and seamless opt-in/opt-out functionality across all platforms and channels.
- Shared suppression lists across vendors and channels – if a user opts out through one system, they must be removed from all related campaigns.
This requires a more integrated back end and tighter coordination between marketing teams and third-party platforms.
Short Code vs. 10DLC: What’s the Right Choice?
| Feature | Short Code | 10DLC |
|---|---|---|
| Recognition | Highly recognizable | Looks like a regular phone number |
| Speed | High throughput (ideal for sweepstakes) | Limited throughput (1–15 msg/sec) |
| MMS Support | Yes | Usually no |
| Approval Time | 8–10 weeks | ~1 week |
| Cost | Higher | Lower |
| Sharing Across Brands | No – as of 2025 | Yes – for now |
For national campaigns and promotions requiring quick, reliable delivery short codes remain the gold standard. But for smaller, less time-sensitive promotions, 10DLCs may be a viable, lower-cost alternative.
What Should Brands Do Now?
Planning ahead is essential. Marketers will need to account for longer lead times and higher compliance costs when budgeting SMS campaigns.
To prepare for these changes, brands should:
- Secure a short code well in advance of campaign launch.
- Draft and publish SMS Terms & Conditions and a compliant Privacy Policy.
- Streamline opt-out management across all systems and channels with real-time sync.
- Evaluate budget and timelines with these new requirements in mind.
- Train your broader team (marketing, dev, legal, support) on the evolving rules and audit implications.
Key Takeaway
The CTIA’s new regulations raise the bar for consumer protection but they also open the door for brands to lead with trust and transparency. By taking action now, you can stay ahead of compliance deadlines, avoid last-minute stress, and set your SMS campaigns up for stronger performance in the months ahead.
At Votigo, we’re here to help you navigate the changes – from launching SMS sweepstakes to designing user experiences that check every compliance box. Have questions? Reach out anytime – we’re ready to provide the expert guidance you need to make your next campaign stand out and succeed.
