Deactivated phone numbers for USA

These guidelines are relevant for SMS and MMS compliance in the USA.

A deactivated phone number is one that a mobile operator has taken out of service for an end user, either because the end user has switched operators or has otherwise closed their account. Eventually, all deactivated numbers are recycled and activated for new subscribers. What this means is that it's easy to mistakenly send a text message to a phone number that has been reassigned to an end user who has not opted into your program.

This is important for messaging in the US because the Federal Communications Commission (FCC) considers this spam and can impose fines for sending a message to a user who has not opted in. Fines can be up to $1,500 per MT message per end user, and you may also be subject to a class action lawsuit.

Complicating the situation further is the fact that mobile operators do not keep numbers inactive for the same amount of time. Some reassign a deactivated number in as little as two days, while others wait 50 days before reassigning a number.

Example: How a mobile phone gets deactivated

A business has Jennifer's phone number and her consent to receive text messages. In other words, Jennifer has explicitly "opted in" to the business's messaging program.

One day, Jennifer switched her mobile phone service from one operator to another, giving up the phone number that she used to opt into the program. In other words, Jennifer did not port or take her mobile phone number with her when she switched mobile operators. The mobile operator puts her phone number on its deactivation list. This particular operator keeps deactivated numbers inactive for two days.

If the business attempts to send a text message to the phone number during the two-day deactivation period, the message will fail and the business will receive an error code from Infobip indicating that the number is currently in an operator's deactivation file. However, after three days, the mobile operator re-assigns the deactivated phone number to another subscriber. Now if the business attempts to send a text message to the phone number, the message will succeed because the number is no longer deactivated; however, the end user (who is not Jennifer) will be confused and perhaps annoyed about receiving a text they did not request. Unfortunately, this constitutes spam and exposes the business to statutory penalties associated with the TCPA. It does not matter that the consumer was on an unlimited messaging plan or that you sent the messages as Free To End User (FTEU); the message is still considered spam because the new phone number owner did not opt in to receive it.

How Infobip helps

Infobip helps to mitigate the risk of sending messages to deactivated numbers by providing Deactivated Phone Numbers reports ("Deact" reports). We provide Deact reports to help you keep your phone number lists current. The reports originate from the mobile operators and contain the phone numbers associated with deactivate and disconnect events in their systems. By making the reports available, you can keep your records up to date such that you do not inadvertently send MT messages to phone numbers that are no longer opted into your programs.

To retrieve the reports from the mobile operators, use the Number Activation State API (opens in a new tab). For further details about retrieving the reports, see Number activation state.

What Infobip expects of you

Retrieving and processing the deact reports daily is imperative.

You must request access to the deact reports from your Account Executive or Infobip Support.

Use the information to remove deactivated phone numbers from your messaging contact list before they are assigned to new subscribers. Mobile operators are allowed to reassign an inactive phone number within as little as two days of deactivation, so you should retrieve and process the deact reports daily.

We also recommend that you contact the previous owner of a deactivated number to request that they opt in with their new phone number. If you choose not to do this, then you should not send messages to them until they opt in after the date the phone number first appears in the Deactivated Phone Numbers report.

Mobile operators that provide deactivated phone number reports

The largest US mobile operators provide deact reports, however, many smaller operators do not. Of those operators that do provide the information, they do it differently due to the lack of an industry standard. A given report can contain deactivate/disconnect events from a specific mobile operator and may contain additional information such as how long the phone number will remain deactivated before it is recycled and given to a new subscriber. For mobile operators that have MVNOs, deactivation information for these operators is included in the mobile operator's deactivation file.

The information in the table below is subject to change. Infobip will update the table as we process reports from additional mobile operators. We make all reports available daily and the content of each report is incremental, meaning that it contains only phone numbers for which the deactivation status changed from the previous report.

US Mobile operators providing deact reports

• Deact File Name is the name of the file available from Customer Center Reporting
• Age of data refers to when a phone number was deactivated
• Deactivation period is the number of calendar days a phone number is deactivated