New Toll-Free Verification Requirement: Privacy Policy and Terms & Conditions URLs Become Mandatory

Effective September 15, 2026, businesses submitting new Toll-Free Number (TFN) verifications will be required to include direct links to their Privacy Policy and Terms & Conditions pages.

The new requirement, announced by Sinch, applies to all new Toll-Free verification submissions and reflects the messaging industry's continued focus on stronger compliance standards and consumer transparency.

While the update itself is straightforward, it reinforces a broader trend across business messaging: successful onboarding increasingly depends on more than simply completing a registration form.

What's Changing?

Beginning September 15, 2026, every new Toll-Free verification submission must include publicly accessible URLs for:

• Privacy Policy
• Terms & Conditions

The requirement applies regardless of how the verification is submitted, including:

• Toll-Free Verified Sender Form
• Bulk Verification File
• Verification API (updated September 14)

Existing Toll-Free verifications are not required to be resubmitted under the new rules.

What Needs to Be Included?

Simply having a Privacy Policy or Terms & Conditions page is no longer enough. Both pages must contain specific messaging-related disclosures and be directly accessible via the submitted URLs.

Terms & Conditions should include:

• Brand or program name
• Description of the messaging program
• Message frequency disclosure
• "Message and data rates may apply" language
• HELP and STOP instructions
• Customer support contact information
• A direct link to the Privacy Policy
• A statement that carriers are not liable for delayed or undelivered messages

Privacy Policy should clearly explain:

• What customer information is collected
• How that information is used
• That SMS opt-in data and mobile information are not shared with third parties or affiliates for marketing or promotional purposes

Additionally, businesses should verify that both pages are publicly accessible and linked directly—not redirected through a homepage or landing page.

Opt-In Flows Matter Too

The announcement also reinforces several existing expectations around customer consent.

Businesses should ensure that:

• The opt-in experience matches the messaging use case submitted for verification.
• Consent is collected specifically for the SMS program and not bundled with unrelated agreements.
• Required disclosures appear adjacent to the phone number entry field.
• Consent checkboxes are unchecked by default.
• Message frequency, HELP, STOP, and "Message and data rates may apply" disclosures are clearly presented.

These requirements help ensure consumers understand exactly what they're signing up for before providing consent.

The Bigger Picture for Toll-Free Messaging

For years, Toll-Free messaging was often viewed as a simpler alternative to 10DLC registration.

That distinction continues to narrow.

Earlier this year, the industry introduced expanded Toll-Free verification requirements designed to strengthen onboarding and reduce messaging abuse. This latest update builds on that momentum by extending compliance expectations beyond the verification form itself to include supporting legal documentation and customer-facing opt-in experiences.

Like 10DLC, Toll-Free onboarding increasingly involves validating not only the messaging campaign, but also the broader customer journey—including opt-in flows, legal disclosures, and publicly accessible Privacy Policy and Terms & Conditions pages.

For software platforms and businesses, compliance should be viewed as an ongoing operational process rather than a one-time registration task. Preparing these materials before submitting a verification can help reduce delays, avoid unnecessary revisions, and improve the likelihood of a successful approval.

Related reading: Toll-Free Messaging Verification: What Changed on January 1, 2026

Before You Submit a New Toll-Free Verification

Use this checklist before September 15:

• Create dedicated, publicly accessible Privacy Policy and Terms & Conditions pages.

• Confirm both pages include the required messaging disclosures.

• Verify your opt-in flow accurately reflects your messaging program.

• Include HELP, STOP, message frequency, and "Message and data rates may apply" disclosures.

• Ensure Privacy Policy and Terms & Conditions URLs point directly to the appropriate pages.

As messaging compliance continues to evolve, staying ahead of these requirements can make onboarding smoother for both messaging providers and the businesses they support.