How to text tenants legally comes down to two separate problems. Carriers decide whether your message gets delivered at all. Federal law decides whether you were allowed to send it. URBI treats resident SMS as one of four channels, so a building is never stranded on the hardest one.
Almost nobody writes about this, and it is the wall every property manager hits the moment they try to text a whole building. The two problems get conflated constantly.
This is general information, not legal advice. Carrier requirements and FCC rules change, and this area has moved twice in the last two years. Have your own counsel review any messaging program before you launch it.
Why do building texts stop arriving without anyone getting an error?
Because message filtering is silent by design. The wireless industry's own messaging guidelines state that "All Service Providers may filter or block Unwanted Messages before they reach Consumers". Nothing bounces back. Your sending tool shows the message as sent.
The manager finds out three days later, when a resident says they never heard about the water shut off. That is the carrier half. The legal half fails just as quietly, and surfaces as a demand letter.
What is A2P 10DLC, and why is it a carrier rule rather than a law?
A2P 10DLC is the registration system US carriers use to decide whether they will deliver application to person traffic sent from a standard ten digit number. No statute created it. The carriers built it and enforce it by filtering traffic that does not comply.
Breaking it produces a delivery problem, not a lawsuit. Doing it correctly gives you no legal protection at all. Registration proves who you are to a carrier. It says nothing about whether the resident agreed to hear from you. The Campaign Registry is blunt about its own limits, stating that it does not review, approve, or reject campaigns.
What does brand registration actually check?
It checks that the sender is a real, identifiable business. The Campaign Registry requires an EIN when a brand is added, and says "This allows TCR to verify the identity of the Brand, which is a requirement for any campaign to be registered on 10DLC".
For a building, the live question is which entity registers: the management company, the individual condo corporation, or one brand with a campaign per property. A registered name that does not match what residents see is the mismatch vetting looks for.
What is a campaign, and why does the use case matter?
A campaign is the description of what you will send, and the use case is the category you file it under. The Campaign Registry describes a campaign as the use case of your messaging.
Building traffic is rarely one thing. A maintenance notice, a rent reminder, a package alert, and an amenity promotion are four different messages. If your campaign says customer care and half your traffic is promotional, you have described your program inaccurately.
Throughput follows from the same two inputs. The Campaign Registry explains that throughput is determined by who is sending the message and what is being sent, not by how many numbers you attach.
The industry calls the resulting rating a trust score, though registry documentation is thinner on that term than vendor marketing suggests. Brands can be vetted by third party partners who, in the registry's words, conduct assessments to determine the legitimacy, trustworthiness, or compliance of businesses. Send several hundred notices at once and throughput decides whether tomorrow's shut off notice lands tonight or trickles out for an hour.
Should the building use a ten digit number, a toll free number, or a short code?
A ten digit number, in almost every case. It is the only one a resident can call back.
| Sender type | What it is | What it takes to send | Where it fits a building |
|---|---|---|---|
| Ten digit long code (A2P 10DLC) | A normal local number, area code and all | Brand and campaign registration, then carrier approval. A national carrier's support page states that sanctioned 10DLC senders must be registered before campaign messages are approved for delivery | The default for a single building or a portfolio |
| Toll free number | A number in the 800, 888, 877, 866, 855 or 844 ranges | Text enablement through the registry Somos administers as the FCC appointed administrator, with authorization from the number's responsible organization. A separate track from 10DLC registration | A central number for a management company. Reads as corporate, not as your building |
| Short code | A five or six digit code | Leased through the US Short Code Registry, a CTIA service mark, then a campaign is submitted through a provider and approved | Overkill for one building. Residents cannot call it back |
None of the three changes your consent obligations. A short code does not exempt you from the TCPA. It changes the carrier process, nothing else.
What does the TCPA require before you text a resident?
Consent, and the standard depends on what the message says. In its 2015 omnibus ruling the FCC confirmed that text messages are calls subject to the TCPA, and that consent must be in writing for telemarketing but can be oral or written for informational messages. That sentence is the whole framework. Everything else is applying it.
| What you are sending | Consent standard | Building examples |
|---|---|---|
| Informational or transactional | Prior express consent. Oral or written | Water shut off notice, elevator outage, package ready, booking confirmed, AGM reminder |
| Advertising or telemarketing | Prior express written consent, with a signature and the required disclosures | Renewal offer, parking upsell, storage locker promotion, a partner discount, a referral bonus |
| A message that mixes both | Treat it as the higher standard | A maintenance notice with a leasing offer stapled to the bottom |
Prior express written consent is a defined term with teeth. The rule requires an agreement in writing bearing the signature of the person called, plus a clear and conspicuous disclosure telling the signer they are authorizing these messages and need not sign as a condition of getting the goods or services. That last clause is why bundling marketing consent into a lease fails.
The TCPA carries a private right of action, with statutory damages set per violation and a court able to raise the award for a willful or knowing violation. Per message damages multiply quickly across a resident list.
Filing volume is not slowing. WebRecon counted 250 new TCPA filings in June 2026, 191 of them class actions, with year to date filings up 34.3 percent, in its monthly litigation statistics. Public data does not break that out by industry. Treat it as a category signal, not a rental statistic.
What changed in the 2024 and 2025 FCC revocation rules?
Opting out got much easier for the resident and much harder to ignore for the sender. In February 2024 the FCC held that a called party may revoke consent "using any reasonable method to clearly express a desire not to receive further calls" or texts. The rules took effect April 11, 2025, per the Federal Register notice. Four things follow:
- Replying with stop, quit, end, revoke, opt out, cancel or unsubscribe is a reasonable revocation per se, as is the website or number you designated for the purpose
- Any other method, such as a voicemail or an email to a number or address meant to reach you, creates a rebuttable presumption that consent was revoked
- Revocation must be honored within a reasonable time, not to exceed ten business days from receipt
- You may send one confirmation message with no marketing in it, and within five minutes it is presumed to fall inside prior express consent
Read the second bullet again. A resident replying to a building email with "please stop texting me" is a revocation. Nobody on your team will recognize it as one.
Molly Arranz, a partner at Amundsen Davis, wrote in March 2025 that the business "bears the burden of proof" when it argues an opt out was not made in a reasonable manner. You do not get to require one magic word.
The revoke everything provision is partially on hold. The FCC waived the part of the rule forcing a revocation of one informational message type to apply to unrelated robocalls and robotexts from that sender. In January 2026 it extended that waiver, ordering that "the effective date of section 64.1200(a)(10) is extended to January 31, 2027 to the extent discussed herein". The order is explicit that the waiver goes no further. Every other revocation obligation is live now.
The one to one consent rule was struck down. The FCC had adopted a stricter written consent rule aimed at lead generation. The Eleventh Circuit vacated it, the mandate issued April 30, 2025, and the FCC conformed its rules to a court decision nullifying the first full paragraph of the revised prior express written consent rule, effective August 29, 2025. Consent language drafted against the stricter version now aims at a rule that does not exist.
Does a lease signature or a phone number on the resident record count as consent?
Partly, and the honest answer is narrower than most managers want. The FCC's position is that a consumer who simply hands over a phone number "consents to informational messages closely related to the service they signed up for", absent instructions to the contrary. That June 2025 ruling restates precedent going back to 1992.
A phone number on a lease is a decent argument for operational messages about the tenancy, and not for anything else. The same ruling says the consent does not extend to texts that include an advertisement, and that the person keeps the option to revoke. That leaves a building here:
- Reasonably defensible. A notice about their own unit, the building's systems, or a service they use
- Weak. A text about a service they never signed up for, from an entity not named on their lease
- No. Anything promotional, without separate written consent meeting the disclosure requirements
- Also no. Consent inherited from a previous owner, a prior management company, or a spreadsheet nobody can source
Stop relying on inference. Capture consent explicitly at move in, as its own item with its own timestamp, naming the message categories the resident agrees to. Our move in checklist for managers is the right place for it, because it is the one moment a resident is already signing.
What about a water shut off, a fire alarm, or an evacuation?
There is a federal emergency exception, and it is narrower than the word emergency suggests. The rule defines emergency purposes as "calls made necessary in any situation affecting the health and safety of consumers". It turns on the condition, not the label you attach. The safe ground:
- Strong. A fire alarm, a gas leak, an evacuation order, contaminated water, a structural failure
- Arguable. A same day loss of water or heat. The closer the condition sits to health and safety, the better the argument
- Weak. A scheduled shut off next Tuesday, an elevator upgrade notice, an inspection reminder. These concern the property, not health and safety
- No. A rent reminder, a lease renewal, an amenity announcement. Marking it urgent in your software changes nothing about the legal analysis
Do not build a program that depends on the exception. It is a backstop, not a workaround for a thin consent record. A building that plans its notification chain in advance is not making this call under pressure, which is why a written emergency preparedness plan beats any single channel.
What happens when a resident opts out and then there is an emergency?
This is the genuinely hard one, and there is no clean answer inside SMS alone. A resident who texts STOP has revoked consent for the messages that required it. The emergency exception may still cover a true health and safety message. But you are betting on it at the moment you cannot afford to be wrong.
The resolution is to stop treating SMS as the notification system. It is one channel in a system that should have several.
- An opt out from building texts is not an opt out from the app, push, email, or the lobby screen
- When someone opts out, log what they opted out of and confirm through another channel what they still get
- Keep the emergency path structurally separate from the routine path
- Keep the notice methods your lease or state law already requires. A text does not replace a posted or delivered notice
A building with four working channels has an answer here. A building whose entire contact strategy is a phone number does not.
Which records do you need to keep, and how many are there?
Three, and most buildings keep one. Consent, the message, and the opt out are separate records, and a dispute turns on whichever one you are missing.
| Record | What it has to show | Where it usually fails |
|---|---|---|
| Consent | Who gave it, when, how, the wording they saw, and which categories it covered | A checkbox with no timestamp and no stored copy of the language |
| The message | The text sent, the send time, the recipient list, and whether it was delivered | Sent from a personal phone, or a tool that purges history after ninety days |
| The opt out | The request in the form it arrived, the date received, and when suppression took effect | A verbal request to a concierge that never reached the system |
The third row is what the 2024 rules made expensive. Revocation can arrive by voicemail, by email, or at the front desk, so the record has to capture requests that never touched the texting tool. A resident telling a concierge to stop texting them is now a compliance event.
Why do buildings end up with a mess in the first place?
Staff texting residents from personal phones. That habit sits outside every system, every consent record, and every opt out list you maintain.
It starts reasonably. A superintendent texts a resident about access for a repair from his own phone, because it is faster. Six months later:
- No consent record exists for those numbers
- The history lives on a device the building does not own
- An opt out sent to that phone never reaches the building's suppression list
- When the superintendent leaves, the thread history leaves with him
- A dispute comes down to screenshots, which prove very little
There is a privacy problem too. Staff personal numbers end up in residents' phones, and residents text them at midnight. The fix is not a policy memo. It is giving staff a channel easier than their own phone that keeps a record.
Where does URBI fit?
URBI's answer is that SMS should not carry the whole load. Arthur, the resident facing AI, handles voice, SMS, email, and in app chat, with each building on its own phone number. The building is never dependent on the channel with the heaviest consent rules. A resident who opts out of texts still gets push, email, and the post in the app. URBI was built around that redundancy.
The second piece is proof. News posts carry three urgency levels and three delivery modes, and the platform tracks who saw each post per resident. That read record is a different class of evidence than a screenshot of a group text. Two details matter:
- An AI urgency scan reads the draft and suggests bumping a NORMAL post to URGENT when it detects language like shut off, alarm, or evacuation, at the moment the classification decision gets made
- Inbound email routes back into the same operator thread through a per thread reply key. A resident replying to a building email does not open a new ticket, so a revocation sent by reply lands where someone sees it
Threads are persistent, searchable forever, and visible to managers, so the message record does not live on anyone's personal phone. Every action writes to a permanent log. For the emergency case, URBI Display's takeover overrides every screen in the building in seconds for a fire alarm, a water shut off, or a board notice, reaching people no consent rule governs. That is the case for real time building communication on a screen, not only in a pocket.
One honest caveat. Registering your brand and campaign for A2P 10DLC is a step you complete with whoever provides your messaging. Do not assume a software vendor has done it for you. Ask, and get the answer in writing.
A resident who uses the app is a resident you can reach without leaning on the channel carrying the most legal freight, which makes resident app adoption a compliance question and not only an engagement one. Same logic on language: Arthur supports ten languages, and a notice a resident cannot read is not a notice, which we covered in multilingual resident communication. Our roundup of the best building communication software covers the field, and URBI for residential buildings shows how the pieces fit.
Common questions about texting residents legally
Do I need A2P 10DLC registration if I only text a few residents a month?
Almost certainly yes, if you send from software rather than thumbing messages on a handset. Carriers classify traffic by how it is sent, not by how much there is. Low volume application traffic from an unregistered number is still filtered, and filtering is silent. Carrier guidance is that sanctioned 10DLC senders must be registered before campaign messages are approved.
How fast do I have to honor an opt out?
Within a reasonable time, and no later than ten business days from receipt. That is the outer limit, not the target. Most platforms suppress a STOP reply immediately. The real risk is the opt out that arrives another way, by voicemail, by email, or in person at the front desk, because those still count and nothing suppresses them for you.
If a resident opts out, can I still text them about a fire?
A genuine health and safety emergency may fall inside the federal emergency exception, which is written around the condition rather than the label. But this is the wrong place to make a close legal call under time pressure. Build the emergency path so it does not depend on that argument: app push, email, lobby and elevator screens, door knocks, and the notice method your lease requires.
What if we already text residents and have no consent records at all?
Start the record now rather than reconstructing one. Send a single properly formed opt in request through a channel you can document, capture the responses with timestamps, and treat the non responders as unconsented for messaging that requires consent. Move them onto app and email notification meanwhile. A thin record you built deliberately beats a thick one nobody can explain.
Texting residents is worth doing. Done properly it is the fastest way to reach someone about their own home. The trap is that both halves fail quietly, one at the carrier and one in a lawyer's office, and neither warns you first. To talk through how a building runs resident messaging across four channels with a per resident record behind it, email us at hello@myurbi.co.
