William Dudley DeMystifying Messaging Series

Demystifying the Mobile Messaging Ecosystem – Part 7: The 25 Billion Text Trap: Why Political Messaging Isn’t Spam, But Still Drives You Crazy

Welcome back for the 7th installment of our “Demystifying the US Messaging Ecosystem” series!  We previously covered:

For a primer on why text messaging became the dominant political tool, you can refer to my April 2023 post, Understanding the Mobile Messaging Ecosystem for Political Campaigns.

The experience is jarringly familiar: your phone buzzes with a high-pressure message, often filled with urgent, even apocalyptic, language, demanding a donation or action. You hit “STOP” for the tenth time this month, shake your head, and categorize it as “spam.”

For many, this is the modern reality of political outreach. But while consumers, and even politicians, frequently label these unwanted texts as “illegal robocalls,” the truth is much more complex—and centers on a fundamental conflict between an antiquated federal law and modern mobile industry standards.

The stakes are immense. Continuing the trend of explosive growth we observed in previous cycles (for more context on historical volumes, see several of my Predictions posts at william-dudley.com), the 2024 election cycle was predicted to generate at least 25 billion political text messages, representing a massive 50% increase over the approximately 15–16 billion messages sent during the 2022 midterm cycle. This volume isn’t just irritating; it’s a multi-billion-dollar compliance challenge that is testing the limits of the entire messaging ecosystem.

The Technical Battlefield: Peer to Peer vs. A2P Compliance

To truly understand why your phone is ringing off the hook, we must clarify the distinction between high-volume political texting and the messaging model most people use.

The TCPA Loophole (The Peer-to-Peer Exemption)

The legal foundation for the political texting surge rests on the Telephone Consumer Protection Act (TCPA) of 1991. The law’s key restriction targets the Automatic Telephone Dialing System (ATDS), defining it as equipment capable of storing or producing telephone numbers using a random or sequential number generator and dialing those numbers automatically.

Political campaigns and their platform vendors have engineered a highly efficient workaround known as Peer-to-Peer texting.

Crucially, we must distinguish this from true Person-to-Person (P2P or more recently referred to as “Consumer texting”) messaging, which is used in the context of conversational exchanges between two consumers, as defined by CTIA guidelines (we covered this distinction in a prior Demystifying post).

The political Peer-to-Peer model works because platforms:

  • Bypass the “automatic” element of the ATDS definition by requiring a human volunteer to load targeted voter list data and then manually click a button to initiate the send of each individual text.
  • The FCC ruled in 2020 that this mandatory human initiation means the system does not meet the statutory definition of an ATDS [3].
  • The Crucial Point: Since the messages are legally not sent by an ATDS, they are exempt from the TCPA’s requirement for prior express consent. This loophole is the fundamental legal basis that enables campaigns to send high-volume, unsolicited texts to citizens whose numbers were sourced from public voter rolls.

The Carrier Mandate (The A2P Reality)

Despite the federal loophole, the mobile industry—represented by carriers and the CTIA—views the traffic differently. Any high-volume text messaging sent by an organization or business for a non-consumer purpose is categorized as Application-to-Person (A2P or “Business texting”) traffic.

This classification is critical because:

  • Carriers mandate that all political messaging—regardless of the technical path (10DLC, Short Code, or Toll-Free)—be classified under the Political Use Case and undergo stringent A2P vetting.
  • The key takeaway is that carriers require vetting and approval before launch for ALL political messaging, effectively imposing their own, stricter, private standards for network integrity and consumer protection, overriding the TCPA’s hands-off approach to Peer-to-Peer traffic.

Carrier Headaches: The Consumer Reporting Crisis

If these Peer-to-Peer texts are technically legal, why are they considered the bane of the mobile ecosystem, often leading to the most severe operational issues for carriers? The answer lies in the inevitable conflict between legal compliance and the ever-evolving consumer experience on their device.

The 7726 Crisis and On-Device Filtering

Political texts are frequently the highest reported source of spam submitted by consumers via the 7726 reporting mechanism. This high volume of complaints creates a massive, legitimate operational headache for carriers, regardless of the message’s legal standing.

Modern mobile phone operating systems (OS) have made reporting this spam easier than ever. For example, iPhones running the latest OS versions may offer a “Delete and Report Spam” button directly below messages from unknown senders, transforming the often cumbersome process of forwarding to 7726 into a seamless, one-button action.

Furthermore, with recent mobile OS updates (such as the latest iOS release), new filtering tools like the Unknown Senders inbox are creating significant friction. Unless a political campaign can establish that they are a “Known Sender,” their texts will often be silently shunted into this secondary folder, meaning the voter may never see the message or the call-to-action.

The Campaign’s Defense: To keep texts out of the filtered box, campaigns must encourage Mobile Originated (MO) traffic (where the user texts the campaign first, like a “TEXT VOTE” keyword), or successfully prompt the user to save the organization’s VCF contact card. These steps create a digital “relationship” that tells the device this message is wanted.

Channel Strategy: 10DLC vs. Short Codes

The challenge of establishing “Known Sender” status ties directly into the channel choice, which is constantly debated in the political space:

ChannelKey AdvantageTypical UsersChallenges
Short Codes (5-6 digits)Highest volume, fastest speed, highest trust (due to rigorous setup).National parties, large PACs, Presidential campaigns.High cost, long setup time, lacks “local” feel.
10DLC (10-digit)Local Presence (uses local area code), supports Peer to Peer outreach.State/local candidates, grassroots efforts, federal campaigns seeking a personal touch.Lower throughput (slower sending speeds), higher risk of being dumped into the Unknown Senders inbox.

In reality, most state, local candidates, as well as many federal candidates, rely heavily on 10DLC numbers because they allow for that valuable local outreach via Peer to Peer. However, this local look is precisely what makes them vulnerable to being dumped into the Unknown Senders folder, placing the entire burden of “Mark as Known” on the busy, skeptical voter.

The Baseless Bipartisan Accusations

The aggressive content strategies used to break through the noise often ignite highly public and partisan controversies, which, while technically baseless regarding illegality, still stress the messaging system and carriers.

  • Republican Claims (Voter Integrity Focus): Conservative groups have frequently claimed that texts used by Democratic-affiliated organizations are aimed at voter suppression—for example, by sharing incorrect polling location information or misleading voting deadlines. These accusations, widely amplified in conservative media, often focus on the deceptive content. However, the claim of illegal activity is often unfounded, as the message delivery channel itself is protected by the Peer-to-Peer legal exemption.
  • Democratic Claims (Deception and Tone): Democratic-aligned groups criticize the right for using deceptive senders and extreme emotional urgency. A notable example involved the National Republican Congressional Committee (NRCC), which was widely reported by news outlets, including the Times Union, for sending texts that appeared on recipients’ phone previews as a “CRIME ALERT: Suspicious activity in your area.” Upon opening, the message revealed itself to be a political attack ad [4]. While the sender was a verified, legitimate entity—meaning the accusation of technical fraud is baseless—the deceptive content creates public outrage and further erodes trust in the mobile channel.

This vicious cycle demonstrates that both political parties leverage the unsolicited nature of Peer-to-Peer, resulting in massive spam complaints that force the carriers—not the government—to tighten the rules.

The Suppression of Speech Claim

This conflict boiled over in 2020 when one presidential campaign’s mass text message push, utilizing the Peer-to-Peer loophole, was flagged and temporarily blocked by the anti-spam monitors employed by wireless carriers (Verizon, AT&T, and T-Mobile). The campaign publicly slammed the move, asserting that blocking political text messages—which they argued were compliant with the lenient FCC rules—was a “suppression of political speech” and an effort to interfere with the election. Carriers maintained that the blocking was a purely technical action, triggered by the massive, concentrated volume of over one million messages, which resembled malicious spam behavior. This incident perfectly captures the industry’s dilemma: carriers must enforce self-regulatory standards for A2P network integrity, even when doing so puts them in the politically charged crosshairs of First Amendment speech claims.


Campaign Verify: The Unifying Identity Layer (The Exposé)

The industry’s solution to injecting trust and transparency into this fractured system is Campaign Verify (CV), a non-partisan effort that ensures identity is not the weak link in the chain.

  • What It Is: Campaign Verify is a non-partisan, non-profit identity solution for US political organizations. Its sole function is to prove the political entity is who they say they are, validating their registration against FEC or state/local election authority filings and issuing an Authorization Token.
  • The Role of the Token: This token is the mandatory identity credential submitted to The Campaign Registry (TCR). It tells the entire mobile ecosystem that the organization is legitimate. This system is essential because it prevents bad actors from spoofing the identity of real campaigns, thereby addressing the misinformation issue at its source: the sender’s integrity.

The New Compliance Horizon

This mandatory vetting is expanding to ensure all high-volume traffic adheres to the same standard:

  • Key Deadline: Effective February 17, 2026,  one or more major carriers will require a Campaign Verify Authorization Token for all political Short Code and Toll-Free campaigns, unifying the vetting standard across every premium A2P channel [5].

The Privacy Policy Blockage Incident

Based on my own industry experience advising (and even personally vetting many thousands of) 10DLC campaigns, a critical real-world failure point prior to the 2024 election for some political 10DLC rollouts proved carrier compliance is the ultimate gatekeeper:

  • The Conflict: Carriers temporarily blocked campaigns tied to the nation’s largest funding platforms, including ActBlue (Democratic) and WinRed (Republican). The root cause? The organization-level Privacy Policies violated strict carrier A2P rules by containing language that allowed for the selling or sharing of donor/voter phone numbers.
  • The Resolution: This was not a minor issue; it stopped national and state messaging campaigns in their tracks. The only solution was for individual candidate committees to draft and publish custom, candidate-level Privacy Policies that explicitly guaranteed no sharing/selling of phone numbers. Only after this change were their A2P campaigns approved.

This incident proves that carrier standards for consumer protection and privacy—enforced through the A2P vetting process—are the ultimate gatekeepers for high-volume political communication. Identity and privacy vetting truly trump political power.

Conclusion: The Path to Trust

The “25 Billion Text Trap” is not a failure of lawlessness; it is a symptom of a deep technical conflict. Campaigns operate legally in the vacuum created by the TCPA’s outdated ATDS definition, but they are constantly running up against the modern, practical consumer protection standards enforced by mobile carriers and device manufacturers.

Tools like Campaign Verify and rigorous A2P vetting are essential because they force identity and privacy compliance where the law is silent, helping to filter out the most egregious fraud and giving the carriers the necessary leverage to manage the volume of “spam.”

While advanced channels like RCS Political Messaging are on the horizon (expected around 2027 for Political texing) and will offer verified sender branding, Campaign Verify’s role in verifying sender identity will only become more critical to ensure the branded messages are trustworthy.