TFN Privacy Policy and Terms & Conditions Requirement

What's changing

From 15 September 2026, every new Toll-Free Number verification you submit must include a link to your Privacy Policy and a link to your Terms & Conditions. This applies whether you submit through the verification form, a bulk file, or the API.

If your TFN is already verified, you don't need to do anything. This only affects new verifications submitted from 15 September onward.

This change is being enforced by the TFN registration partners that manage toll-free verification, and matches requirements other major messaging providers are also rolling out around the same date. It's an industry-wide tightening of toll-free compliance standards, not something specific to Sinch Engage.

What you need to do

Before you submit a new TFN verification (or before 15 September if you already have one in progress), make sure you have:

1. A Privacy Policy published on your website

2. A Terms & Conditions page published on your website

3. Both pages live and publicly accessible, not behind a login and not a broken link

What your Privacy Policy needs to say

• What customer data you collect and how you use it

• A clear statement that mobile phone numbers and opt-in consent won't be shared with third parties or affiliates for marketing or promotional purposes. For example: "No mobile information will be shared with third parties or affiliates for marketing or promotional purposes."

What your Terms & Conditions needs to say

• Your brand or program name and a short description of your service

• "Message and data rates may apply"

• How often you'll message people (or a note that frequency may vary)

• How customers can reach you for support (for example, "Reply HELP for help" plus an email or phone number)

• How to opt out (for example, "Reply STOP to opt out")

• A link to your Privacy Policy

• A note that carriers aren't liable for delayed or undelivered messages

• If customers sign up through a web form, the Terms & Conditions link also needs to appear on that sign-up page itself

Common reasons submissions get rejected

• The link is broken or the page doesn't load 

• The link is HTTP instead of HTTPS 

• The link goes to your homepage instead of directly to the policy The page is missing the exact required third-party data-sharing sentence or the carrier liability disclosure 

• Your consent checkbox references the Privacy Policy or Terms & Conditions as plain text instead of a live, clickable link 

• Your sign-up page covers more than one use case but only has one shared consent checkbox, instead of a separate checkbox for each use case 

• The sign-up checkbox on your website is pre-checked (it must be unchecked by default)

Frequently asked questions

Do I need to resubmit my already-verified TFN? No. Only new submissions from 15 September 2026 need these links.

What happens if I submit without them after 15 September? Your submission will be rejected with an error indicating the Privacy Policy or Terms & Conditions link is missing, inaccessible, or missing required content.

Can I combine my Privacy Policy and Terms & Conditions into one page? Yes, as long as the link name makes clear it covers both, and the page includes everything listed above for each.

I don't have a Privacy Policy or Terms & Conditions page. What do I do? Talk to your legal counsel to make sure whatever you publish is compliant with applicable laws for your business and campaign type. We recommend getting this sorted well before 15 September, since building and publishing these pages can take time.

Does this affect how I collect opt-in consent? Not directly, but it's a good time to check your sign-up flow matches the requirements: your opt-in language should identify your business, describe the type of messages you send, disclose "message and data rates may apply," and give clear instructions to reply HELP or STOP. Your Privacy Policy and Terms & Conditions need to be live, clickable links next to your consent checkbox, not just written out as text. If your sign-up page covers more than one use case, each one needs its own separate consent checkbox rather than a single shared one. Consent checkboxes must be unchecked by default.

I'm registering for fundraising or donation messages, is there anything extra I need? Yes. Beyond the standard Terms & Conditions and Privacy Policy content, your consent language needs to explicitly mention that you send fundraising or donation-related messages, not just describe your messaging in general terms. A commonly used version looks like this:

"By providing your mobile phone number and enrolling in the [Program Name] program, you agree to receive recurring [Message Type] text messages from [Business Name], including fundraising and donation-related messages. Message frequency varies. Message and data rates may apply. Reply STOP to cancel or HELP for help. For additional assistance, contact [Customer Care Email Address] or [Customer Care Phone Number]. Wireless carriers are not liable for delayed or undelivered messages. Participation i

Need help?

Contact your Sinch Engage account manager, or raise a support ticket with subject "TFN verification, Privacy Policy and Terms & Conditions."