Compliance

Does A2P 10DLC apply in Canada?

By Blake Cowan, Founder, BitDepth AI ConsultingPublished August 2, 2026

A2P 10DLC is a US carrier framework. Texting Canadian customers is governed by CASL, with penalties up to $10 million. Here is what actually applies.

Does A2P 10DLC apply in Canada?

No. A2P 10DLC is a registration framework created by United States telecom carriers, and it governs application-to-person messages sent to US numbers. Twilio's documentation states it plainly: it is "the standard that United States telecom carriers have put in place," and registration is required for "anyone sending SMS/MMS messages over a 10DLC number from an application to the US."

If you are texting Canadian customers, the law that binds you is CASL, Canada's Anti-Spam Legislation, enforced by the CRTC. The two are not substitutes, and being registered for one tells you nothing about your standing under the other.

What law governs business text messages in Canada?

CASL governs them, and the CRTC enforces it. A text message to a customer promoting your services is a commercial electronic message under the Act, exactly as an email would be.

The practical consequence is that the rules you have to satisfy are about consent, identification and unsubscribe, not about carrier registration. A vendor who answers a Canadian compliance question by citing their 10DLC status has answered a different question.

What consent do I need before texting a Canadian customer?

Either express consent or implied consent. Express consent must be obtained through an opt-in mechanism, as the CRTC specifies, "as opposed to opt-out," and it can be given in writing or orally.

Express consent does not expire, though the recipient may withdraw it at any time. Implied consent can apply in defined circumstances such as an existing business relationship, which is the category most missed-call replies to an existing customer fall into.

Can I text someone back automatically if they called me and I missed it?

In most cases yes, because a customer who just phoned your business has initiated contact and an existing business relationship is one of the circumstances where implied consent may apply. This is why missed-call text back is one of the lower-risk automations a Canadian trades business can run.

It is not unlimited. The reply still has to identify you and still has to carry a working unsubscribe. And implied consent is narrower than express consent, so a missed-call reply is not a licence to add that number to a marketing list.

What has to be in the message itself?

Two things: identification and a working unsubscribe. You must identify yourself and anyone on whose behalf the message is sent, and supply a mailing address that stays valid for at least sixty days after you send it.

The unsubscribe mechanism must be, in the CRTC's words, "simple, quick and easy for the end-user." It must stay valid for at least sixty days after the message is sent, and once someone uses it you must act on it "without delay, and no later than 10 business days after receiving it."

RequirementWhat CASL asks for
ConsentExpress (opt-in, written or oral) or implied (e.g. existing business relationship)
Sender identityIdentify yourself and anyone you send on behalf of
Mailing addressValid for at least 60 days after sending
UnsubscribeReadily performed, valid at least 60 days
Unsubscribe processingWithout delay, no later than 10 business days
Maximum penalty, individual$1 million per violation
Maximum penalty, business$10 million per violation

All figures from the CRTC's CASL guidance, fetched 2026-08-02.

What are the penalties if I get this wrong?

Up to $1 million per violation for an individual and up to $10 million per violation for a business, under the CRTC's administrative monetary penalty regime. Those are ceilings rather than typical outcomes, but they are the reason this is worth ten minutes of attention.

For a small contractor the realistic risk is not a headline penalty. It is an automation configured by a US-built tool that never asked about consent, identification or unsubscribe, because the framework it was designed against does not require them.

So why do vendors keep mentioning 10DLC?

Because most missed-call and SMS automation products are built for the US market first, where 10DLC registration is a genuine and unavoidable requirement. The registration is real, it is just not the thing that makes you compliant in Canada.

If your provider sends through US carrier infrastructure, they may well need 10DLC registration for their own routing. That is their operational problem. Your obligation under CASL is separate and it does not go away because they handled theirs.

What should I actually ask a vendor?

Four questions, in this order. Does the system capture and store consent, and can I see the record. Does every outbound message carry my business name and a valid mailing address. Is there a working unsubscribe, and does it stay live for at least sixty days. When someone unsubscribes, what happens, and how fast.

If a vendor answers those four with specifics, they have thought about Canada. If they answer with "we are 10DLC registered," they have not.

Does this apply to AI receptionists and voice agents too?

CASL governs commercial electronic messages, so the text side of an AI receptionist is squarely in scope. Voice calls are governed separately, primarily through the CRTC's telemarketing and Do Not Call rules rather than CASL.

The practical rule for a mixed system is that every automated text it sends is a CEM and needs consent, identification and unsubscribe, regardless of whether a human or a model composed it.

Not legal advice. This page summarises published CRTC guidance and links to it directly so you can check every claim. It is not a legal opinion, and CASL obligations depend on your specific circumstances. Confirm your position with counsel before relying on it.

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