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Texting merchants: what SMS consent requires

Quick answer

Texting a merchant needs the same prior express written consent as an automated call, plus a second layer the law does not impose: carrier and aggregator rules that require an identified sender, a working opt-out keyword, and campaign registration. The carriers act first and they act without a hearing — a number that draws complaints is filtered long before a regulator hears about it.

Alex MakowskiFounder, Infinite BookingsUpdated 2026-08-302 min read

Two separate rulebooks govern a text message to a merchant, and only one of them is law. The legal layer is the TCPA and its state equivalents. The operational layer is the carriers and the messaging aggregators, who will throttle or block a sending number on their own judgement and on their own timetable.

RequirementSourceWhat happens if you skip it
Prior express written consentTCPAStatutory damages, per message
Sender identified in the messageCarrier rulesFiltering, then blocking
STOP honoured immediatelyBothClaims, and campaign suspension
10DLC campaign registrationCarrier rulesUndelivered messages, silently
No prohibited content categoriesCarrier rulesCampaign rejected outright

The silent failure

The characteristic SMS problem is not a fine, it is delivery. Unregistered or poorly-rated traffic gets filtered without an error — the platform reports the message as sent, the merchant never receives it, and the floor spends a fortnight concluding the leads are dead. Check delivery receipts against replies before you conclude anything about a batch.

Opt-out has to be real

  • STOP, and its common variants, suppress immediately and permanently.
  • A merchant who says "stop texting me" in a sentence has opted out as effectively as one who typed the keyword. Reps have to be able to action that.
  • Suppression propagates to every channel and every tool, not just the one it arrived on.
  • Opt-out survives a CRM migration. This is the one that breaks in practice.

The last two are the same failure as the do-not-call plumbing problem, and they have the same fix: one suppression table that every outbound tool reads before it sends, rather than a flag in whichever system the rep happened to be looking at.

Questions brokers ask

Yes — the same prior express written consent that an automated call to a wireless number requires. A merchant submitting a funding application under a visible disclosure that names texting is the standard way that consent is obtained.

The registration scheme for application-to-person messaging on standard ten-digit numbers. Carriers require the sending brand and campaign to be registered, and unregistered traffic is filtered or blocked. It is a carrier requirement rather than a legal one, which does not make it optional.

Most often unregistered or poorly-rated traffic being filtered silently — the platform reports the message as sent and it never lands. Check delivery receipts, campaign registration status and content for terms that trip lending filters before concluding the leads are unresponsive.

No. The keyword is what automated systems act on, but a merchant asking to stop in plain words has opted out just as effectively, on a call or by email. Reps need a way to record that which reaches every outbound tool.

It is a bad idea on two counts. Carriers filter lending content aggressively, and quoting terms before you have seen statements is the practice that produces the complaints in the first place. Keep the message about the application they submitted.

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