Introduction: The 2026 Compliance Baseline
If you're sending business text messages in the U.S., A2P 10DLC compliance is no longer optional--it's table stakes. The landscape has shifted dramatically over the past year, and 2026 brings even stricter requirements.
Here's what you need to know:
A2P = Application-to-Person (any message sent from a system, app, or AI agent)
10DLC = 10-digit long codes (local-looking phone numbers like 415-555-0198)
As of February 1, 2025, all major U.S. carriers began blocking 100% of unregistered 10DLC traffic--not throttling, blocking. If you haven't registered, your messages simply don't arrive.
But registration alone isn't enough anymore. In 2026, you need to navigate new FCC rules, state-level laws, and increasingly aggressive carrier filtering. This guide covers everything you need to stay compliant--and keep your messages landing.
What Changed in 2025: A Quick Recap
Before we look ahead, here's what happened in 2025 that set the stage for today's environment:
Carrier Enforcement (February 2025)
All unregistered 10DLC traffic now blocked entirely
Fines up to $10,000 per violation for non-compliance
"Snowshoe" messaging (rotating numbers to evade detection) explicitly forbidden
TCR Fee Updates (August 2025)
Brand registration: $4.00 → $4.50
Standard brand vetting: $40.00 → $41.50
New Authentication+ verification: $12.50 for public companies
New CSP Migration fee added
New Registration Requirements
Reseller ID now mandatory if registering on behalf of another entity
Sole proprietors now require an EIN for new registrations
Canadian numbers sending to U.S. recipients now require A2P registration
Terms of Service and Privacy Policy URLs required on opt-in forms (October 2025)
Throughput Limits Now Enforced
T-Mobile: Daily message caps at brand level
AT&T: Per-minute throughput limits at campaign level
Sole proprietors limited to 1,000 messages/day (T-Mobile) and 15 messages/minute (AT&T)
What's New in 2026
2026 introduces several major changes that every B2C company needs to understand:
FCC One-to-One Consent Rule (January 27, 2026)
This is the biggest change of the year. Originally scheduled for January 2025, the FCC's new consent rule finally takes effect on January 27, 2026.
What it means:
Individual consent required for each specific seller--no more blanket consent via lead generators
If a consumer fills out a form that shares their info with multiple companies, each company needs separate, explicit consent
Major impact on lead-gen, affiliate marketing, and shared lead models
FCC Revocation-All Rule (Delayed to January 2027)
Originally planned for 2026, this rule has been pushed to January 31, 2027:
If a consumer says "STOP" to one message type, you must stop all automated messages
Still pending FCC review, but businesses should prepare now
State-Level Laws Taking Effect
States are increasingly passing their own SMS regulations:
Texas SB 140 (September 2025): Expands "telephone solicitation" to include texts; ties violations to the Texas DTPA (treble damages possible)
Virginia SB 1339 (January 2026): Requires honoring text opt-outs for 10 years
Carrier AI Filtering
Carriers now use AI to match your live messages against registered samples in real-time:
Even compliant campaigns can be filtered if traffic patterns raise flags
High opt-out rates trigger automatic filtering
Messages that drift from registered samples get blocked
TCPA Litigation Surge
The legal landscape is harsher than ever:
TCPA lawsuits up 95% in 2025
Class actions up 285% in September 2025 alone
Expect high-profile fines and settlements throughout 2026
The Most Common A2P 10DLC Mistakes in 2026
Even with the best intentions, companies still get tripped up. Here are the most common pitfalls:
1. Assuming Old Registrations Are Still Valid
Campaigns registered in 2023-2024 may need re-verification. Carrier requirements have evolved, and outdated registrations can trigger filtering or rejection.
2. Using Lead-Gen Consent as Blanket Authorization
With the new FCC one-to-one consent rule, shared leads are a compliance minefield. Each seller needs explicit, individual consent.
3. Vague or "Stock" Use-Case Descriptions
Generic descriptions like "notifications" or "customer updates" still get rejected. Carriers want specifics:
Good: "We use AI agents to follow up with insurance leads who requested quotes, provide additional options, and qualify them for phone calls."
Bad: "Customer notifications and updates."
4. Missing Live Opt-In URLs
Carriers now request live, accessible URLs--not just screenshots. Your opt-in flow must be verifiable in real-time.
5. AI-Generated Messages Drifting from Registered Samples
If you're using AI agents for SMS, your dynamic content must still align with approved campaign samples. Carriers are matching messages against registrations in real-time.
6. Ignoring State-Specific Requirements
Texas and Virginia now have stricter rules than federal regulations. If you're messaging consumers in these states, you need state-specific compliance.
7. Not Monitoring Deliverability
High opt-out rates, spam complaints, or unusual traffic patterns trigger carrier filtering--even for registered campaigns. Monitor your metrics weekly.
How Apten Handles A2P 10DLC Compliance
With Apten, A2P 10DLC compliance is fully managed--no paperwork, no guesswork.
What We Handle Behind the Scenes:
Automatic brand and campaign registration with The Campaign Registry (TCR)
Real-time message QA--ensures AI-generated messages stay within approved use cases
One-to-one consent tracking--ready for the 2026 FCC rule
Opt-out handling built-in--automatic STOP/HELP processing with 10-year retention for Virginia compliance
Proactive re-verification--we monitor and update registrations before they lapse
Deliverability monitoring--alerts before your campaign gets filtered
State compliance awareness--messaging adjusted for Texas, Virginia, and other state-specific rules
You focus on building a better lead journey. We handle the maze of carrier rules.
Why Compliance Is Critical for AI Agents
AI agents depend on message delivery. If a message is blocked:
No conversation gets triggered
No follow-up happens
No conversion occurs
That's why Apten was built with compliance as infrastructure--not an afterthought.
Whether it's SMS, voice calls, or email, Apten ensures your outreach is:
Legitimate--carriers recognize and trust your messages
Scalable--run thousands of conversations without manual intervention
Compliant by design
Looking Ahead: RCS and the Future
RCS (Rich Communication Services) is expected to go commercial in mid-to-late 2026. Major carriers--Verizon, AT&T, T-Mobile--are currently in beta with Fortune 500 companies.
What to expect:
RCS will likely require similar registration and compliance frameworks as 10DLC
Pricing models are still under discussion
Apten is already preparing for RCS compliance--when you're ready to expand to rich messaging, your compliance foundation carries over
2026 Compliance Checklist
Use this checklist to ensure you're ready for 2026:
☐ Verify your brand registration is current and matches IRS records
☐ Review and update campaign use-case descriptions (be specific)
☐ Ensure opt-in flows have live, accessible URLs
☐ Update consent collection for the one-to-one rule (if using lead gen)
☐ Audit AI message output against registered samples
☐ Set up 10-year opt-out retention (Virginia requirement)
☐ Monitor deliverability and opt-out rates weekly
☐ Review state-specific requirements (TX, VA, others)
Final Takeaway
A2P 10DLC compliance in 2026 is more complex than ever--but it's also more automatable if you choose the right platform. The penalty landscape is harsher, carrier enforcement is stricter, and new regulations are taking effect.
At Apten, compliance isn't your problem. It's our foundation.
Let our platform handle the complexity--so your messages land, your leads engage, and your sales team wins.
👉 Ready to send smarter, compliant outreach at scale?
Book a demo and we'll walk you through how Apten does it better--and legally.
