1. The Big Update: Mandatory Business Registration
The most significant change effective February 17, 2026, is that the Business Registration Number (BRN) is no longer optional. To prevent spam and align Toll-Free messaging with the strict standards of 10DLC (Local Long Code), carriers now require a government-issued identifier for every new submission.
Key Mandatory Fields
Business Registration Number (BRN): For U.S. businesses, this must be your 9-digit EIN. For Canadian businesses, use your Business Number (BN).
Business Registration Type: You must specify your registration type: EIN, CBN, CRN, NEQ, PROVINCIAL_NUMBER, VAT, ACN, ABN, BRN, SIREN, SIRET, NZBN, UST-IDNR, CIF, NIF, CNPJ, UID.
Legal Entity or Organization Type: Private Company, Publicly Traded Company, Charity / Non-Profit Organization, Government, or Sole Proprietor.
Issuing Country: The country where your business is legally registered.
Privacy Policy Links: Links from business websites containing the language that the SMS Opt-In will not be sold or shared with third parties.
Terms and Conditions Link: Link from business website containing the services agreement between the customer and the services provided.
Opt-In Keyword: This field will be START, YES, BEGIN, or Keyword from the business to restart SMS after a reply of STOP.
2. Critical Deadlines & Enforcement
Milestone | Status | Impact |
Pre-2026 | Optional | BRN fields were recommended but not required. |
Feb 17, 2026 | Mandatory | New submissions without a BRN result in immediate rejection. |
Ongoing | Verification Required | Unverified or "Pending" numbers remain blocked in the US/Canada. |
3. Stricter Opt-In Requirements
Carriers have sharpened their focus on how you collect phone numbers. A simple "They gave us their number" is no longer enough. Your submission must include:
Verifiable Evidence: Direct links to your website’s signup form or screenshots of your "Text-to-Join" Call to Action.
One-to-One Consent: Per the new FCC-backed rules, consent must be specific to your business. You cannot "buy" a lead list where the user agreed to be contacted by "partners."
Privacy Policy Updates: Your privacy policy must explicitly state that SMS opt-in data will not be shared with third parties for marketing purposes.
4. Why This Matters (The "Why")
The industry is closing the "Toll-Free Loophole." Previously, many businesses moved to Toll-Free to avoid the complex registration of 10DLC. Carriers have responded by making Toll-Free verification just as rigorous to:
Reduce Phishing: Ensuring every sender is a legally registered entity.
Increase Deliverability: Verified traffic enjoys higher throughput and fewer "false positive" spam blocks.
Consumer Trust: Standardizing opt-out language (e.g., "Reply STOP to unsubscribe") across all channels.
5. Checklist for a Successful Submission
To avoid delays in verification, ensure your application includes:
Exact Legal Name: Must match your EIN/IRS records perfectly.
DBA: This is the brand name and can be different from the legal business name.
Live Website: No "under construction" pages; must have a footer link to a Privacy Policy.
Business Registration Number (BRN): For U.S. businesses, this must be your 9-digit EIN. For Canadian businesses, use your Business Number (BN).
Business Registration Type: You must specify your registration type: EIN, CBN, CRN, NEQ, PROVINCIAL_NUMBER, VAT, ACN, ABN, BRN, SIREN, SIRET, NZBN, UST-IDNR, CIF, NIF, CNPJ, UID.
Legal Entity or Organization Type: Private Company, Publicly Traded Company, Charity / Non-Profit Organization, Government, or Sole Proprietor.
Issuing Country: The country where your business is legally registered.
Business Contact Email: This email must match the domain of the business website and be visible on the business website.
Use Case Clarity: A detailed description of why you are messaging (e.g., "Two-factor authentication" or "Appointment reminders").
Summarize Use-Case: This is a description of what you are sending to the client or customer. This must match the opt-in disclosure.
Opt-In Workflow: This is a description of how a client or user can access the SMS opt-in.
Sample Messages: Must include your Brand Name and Opt-out language (e.g., "Hi from Acme Corp! Your order is ready. Reply STOP to opt out.")
Opt-In Workflow Image URL: This is a link to the actual opt-in where a user or client has a call to action, consenting to receive SMS from the business. This can be a Digital, Verbal, Paper, or by Inbound message opt-in.
Privacy Policy Links: Links from business websites containing the language that the SMS Opt-In will not be sold or shared with third parties.
Terms and Conditions Link: Link from business website containing the services agreement between the customer and the services provided.
Opt-In Keyword: This field will be START, YES, BEGIN, or Keyword from the business to restart SMS after a reply of STOP.
6. Company Verification
Subject to Decline: When submitting for a Private Company, Publicly Traded Company, Charity / Non-Profit Organization, and Government entity, and the toll free submission is rejected for - business registration number is missing or invalid. Then a link to a screenshot of the Business Registration form will need to be attached to the submission before resubmitting, because the information that was entered in the business details, did not match the official Business Registration form.
7. The Sole Proprietor’s Path in 2026
In previous years, sole proprietors often operated in a "gray area" of Toll-Free SMS. As of early 2026, the industry has standardized the requirements to mirror the 10DLC (local number) verification process.
The EIN Requirement
While a Social Security Number (SSN) was occasionally accepted in the past, carriers now strongly prefer—and often mandate—an Employer Identification Number (EIN) for all Toll-Free verifications.
Even if you have no employees, obtaining an EIN from the IRS is now considered the "best practice" for instant approval.
Submissions without an EIN (using the SOLE_PROPRIETOR classification) can now be subject to Manual Verification. This involves uploading a government-issued ID and sometimes a "live selfie" to prove identity, which can add more time to your approval time.
When submitting as a Sole Proprietor:
Business Registration Number: Leave this field blank.
Business Registration Type: Leave this field blank.
Legal Entity or Organization Type: Select Sole Proprietor.
If a sole proprietor toll free submission is rejected for - business registration number is missing or invalid. Then we will need to submit for a manual verification to the carrier aggregators. Email our team directly at tfverification@telnyx.com with any business registration forms and we will file an appeal for a manual verification.