10DLC Sole Proprietor Registration: How to Register Without an EIN

The table below collects the points an agency usually needs before it decides which path a client belongs on. Every row comes from Twilio's published documentation and blog posts, because Twilio is the provider whose sole proprietor pages we were able to open and read in full. Other providers register through the same registry, but their limits and screens may be worded differently, so check the provider the client really uses.

We could not open a page from The Campaign Registry itself that states these rules, so where a row describes a registry limit it is Twilio's description of it.

Twilio's documentation describes the Sole Proprietor brand as intended only for customers in the US and Canada who do not have a tax ID. It defines a tax ID as a US Employer Identification Number or a Canadian Business Number. People in this group typically report business income under their own Social Security number or Canadian Social Insurance Number. The registration does not ask for that personal number.

The test is the tax ID, and the legal label on the business does not change it. Twilio's page on collecting business information says a sole proprietorship that has an EIN must register as a Low-Volume Standard or Standard brand. Its ISV walkthrough goes further and says US LLCs are ineligible even when the IRS treats them as a sole proprietorship, because, in Twilio's words, all US LLCs have an EIN. That is Twilio's statement of the rule. If a client's LLC has never been issued an EIN, ask the provider before choosing a path.

Twilio's launch post from April 2023 also names hobbyist developers, such as students or people building personal projects, as an intended group. A business outside the US and Canada cannot use this path at all and needs a Standard or Low-Volume Standard brand to send 10DLC messages to US numbers.

This is the mistake that costs agencies the most time. The sole proprietor form is shorter, so it is tempting to use it for any small client. Twilio's documentation warns against it directly: registering a business that has an EIN as a Sole Proprietor brand will incur fees and will affect the business's ability to send A2P 10DLC messages.

The ISV walkthrough explains the mechanics. A reseller may rely on the customer to say whether they have a tax ID. If a customer who declared eligibility is later found to have an EIN or equivalent, the campaign registration will error. The reseller or the customer then pays the associated fees again and re-registers as a Standard or Low-Volume Standard brand. Until that is done, the customer cannot send 10DLC SMS in the United States.

Twilio splits the registration into a starter profile, a brand and a campaign. The starter profile holds the person's first and last name, email and contact phone number. The email has to be well formed, on a valid domain, and not from a disposable-address service. The contact phone can be a landline or a mobile.

The address must be a valid US or Canadian business or personal address. Twilio's ISV walkthrough says PO boxes are allowed. The brand name is the business's real name. For most sole proprietors that is the person's first and last name, and a doing-business-as name may be used. Twilio says the brand name cannot be an internal identifier such as an account ID or an email address. A business vertical is optional.

For resellers, Twilio is explicit that the registration must carry the customer's information and never the reseller's own. An agency that enters its own address or mobile number for several clients will run into the reuse limits described below, and the brands will not describe the businesses that are really sending.

A Standard brand is matched against business records by its tax ID. A sole proprietor has no such record, so the check is on the person. Twilio's documentation says an SMS one-time passcode is sent to the mobile number supplied with the brand, and that the person must respond within 24 hours. If the window is missed, the registrant can return to the same screen and trigger the passcode again.

The mobile number has conditions. Twilio says it must belong to a valid US or Canadian mobile device and cannot be a number acquired from a communications platform provider such as Twilio. In plain terms, it has to be the owner's real handset on a mobile carrier, and a virtual number will not pass.

The reuse limits are counted across the whole registry. Twilio states that one mobile number can verify no more than three Sole Proprietor brands and that registrations made through other vendors count toward the three. An email address and a postal address can each be used for at most ten brand registrations, again counting other vendors. An agency that tries to verify clients with a shared office mobile will hit the ceiling at the fourth client.

Twilio's ISV walkthrough states three structural limits: one Sole Proprietor brand per unique customer, one campaign per brand, and one phone number per campaign. Its direct registration page adds a detail that catches people out. If the messaging service attached to the campaign holds several 10DLC numbers, the system picks one of them at random as the verified route, and the others are not verified for application-to-person traffic.

The use case is fixed. The only campaign use case available on this path is named Sole Proprietor, so there is no choice between marketing, account notifications and the other standard use cases.

Twilio's launch post of 13 April 2023 lists the carrier limits for the brand type as 1,000 messages a day per campaign on T-Mobile and 15 messages a minute per campaign on AT&T. Those figures come from a 2023 post. We did not find a newer Twilio page that restates them, and carriers can change limits, so confirm the current numbers in the provider console. For comparison, an earlier Twilio post describes the Low-Volume Standard brand as meant for fewer than 6,000 message segments a day.

The brand step is fast. Twilio says brand approval typically takes a few minutes once the passcode is confirmed. The campaign step is where the waiting happens. Twilio describes campaign review as manual, taking up to five business days for standard cases, and suggests contacting support if a campaign is still in progress after ten days. A campaign shows as in progress, then as verified or failed. Messages can be sent only after the campaign is fully approved.

The campaign form asks for a description, at least two sample messages and up to five, each of up to 1,024 characters, links to a privacy policy and to terms, a description of the message flow and opt-in, and at least one phone number. A one-person business often has no privacy policy page at all, and a campaign cannot be completed without one.

If a campaign fails, Twilio says it can be edited or deleted and resubmitted. The reasons campaigns are rejected are covered in a separate post on this site, and they apply to sole proprietors as much as to anyone else.

Twilio's direct registration page says a one-time brand registration fee applies and that the campaign is subject to a verification fee charged at external vetting. The page tells the reader to see the amount shown on screen and links to a separate pricing article. We could not open that pricing article, so this post does not state dollar amounts for the sole proprietor path. The only price printed on the page we read is an example of a phone number at 1.40 dollars a month.

Fees are charged again if the registration has to be redone. That is the cost that matters most here: a client registered on the wrong path pays twice and waits twice. Our separate post on 10DLC registration cost covers the published fee schedules across brand types.

The choice is usually made for you by the tax ID. With an EIN, the sole proprietor path is closed. Without one, the sole proprietor path is the only one open, and getting an EIN is what opens the others. Whether a business should obtain an EIN is a question for the owner and their accountant.

The Sole Proprietor brand does not convert into a Standard brand. Twilio's documentation describes re-registering as a Standard or Low-Volume Standard brand, with its fees, when a customer turns out to have a tax ID. Plan for a fresh brand and a fresh campaign review if a client grows.