As Marketers, we all know the immense value Shopping Cart Abandonment [SCA] messaging brings to the table. SCA messaging drives revenue, builds affinity and keeps your brand top of mind – to name just a few. If you’re looking to build out your omni-channel communication strategy by adding SCA text messaging, but need help navigating the compliance requirements - you’ve come to the right place!

Before I get into the compliance requirements, let’s start with a little history for context. In May 2020, T-Mobile announced a policy change in their handbook regarding shopping cart abandonment text messaging. The changes were designed & implemented as a reaction to negative consumer feedback specifically related to SCA messaging via text. Consumer feedback indicated:

#1: Unaware they had agreed to receive SCA Text Messaging at point of acquisition.

#2: Alarmed they were receiving so many SCA Text Messages on a consistent basis.

As we all know, attaining a 100% compliant program depends on the attention paid to the details. Here is every requirement you’ll need to address as you launch your SCA text program:

  1. Calls-to-Action must indicate within the opt-in T&C’s language that your text message program may deliver content associated with shopping cart reminders.
    a. Example CTA Compliance Language: Recurring automated marketing messages and cart reminders will be sent to the number provided at point of opt-in.
  2. Double Opt-In language within the text message a subscriber receives must include reference to cart reminders.
    a. Example Text Compliance Language: BRAND: Reply Y to confirm ur interest in receiving promo msgs & cart reminders. Msg freq varies. T&Cs: [INSERT LINK]. Text STOP 2quit, HELP 4info.
  3. Double Opt-In must be included via text for subscribers to confirm they understand terms. 
    a. Of Note: At this point, you have a digital record your subscriber has seen the legal disclosure both within the CTA and the actual text message subscription prompt.
  4. Privacy Policy must explicitly state how information is captured by the ecommerce site to determine (or define) when a cart has been abandoned.
  5. Terms and conditions must reflect the addition of cart reminders.
  6. SCA content
    1. Must be delivered within 48 hours following abandonment.
    2. May not exceed one reminder per cart abandonment, per subscriber.
    3. Must not result in a completed transaction behalf of the customer or process payment. 

Following T-Mobile’s policy enhancements, the Cellular Telecommunications Industry Association (CTIA) released similar guidelines in their 2021 handbook along; however, they included one additional regulatory update: 

  1. SCA content texts must include an opt-out notice to the consumer within the broadcast. 

While these updates may seem like a lot, please keep in mind that T-Mobile is the third-largest carrier in the U.S. History has told me when one carrier implements a policy change, the others tend to follow suit. This being the case, I fully expect all carriers to adopt these changes in the near future. 

If you have any questions about these policy changes, please do not hesitate to reach out to your account manager for more information.

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