This is the post nobody wants to read until they get the letter from the FCC. Or worse, the lawsuit from the homeowner with a TCPA attorney on speed dial.
If you are an HVAC contractor texting homeowners from any kind of bulk SMS system — your dispatch software, your CRM, GoHighLevel, Twilio direct, even a “team SMS” tool — you are operating in a regulated space. Get it wrong and the per-message penalty is $500-$1,500. Per message. The class actions can run six figures.
This guide is the plain-English version. Not legal advice. Talk to a real lawyer if you have a specific question.
The two regulations you have to know
There are two overlapping rule sets:
TCPA (Telephone Consumer Protection Act). Federal law since 1991. Updated multiple times — most recently in 2024 with the one-to-one consent rule. Covers when you can call or text a consumer.
A2P 10DLC. A carrier framework (not a law) that mobile carriers — Verizon, T-Mobile, AT&T — adopted to police business SMS traffic in 2022-2023. Requires every business sending SMS to consumers from a 10-digit long code to register their brand and their campaigns.
You have to comply with both. They are not redundant.
What 10DLC requires
Every shop sending SMS to consumers needs:
-
Brand registration. Your company is registered with The Campaign Registry (TCR). This costs a one-time $4 fee plus an annual $44 vetting fee in most stacks.
-
Campaign registration. Each “use case” you send SMS for is registered separately. Typical HVAC use cases:
- Customer care (appointment confirmations, dispatch ETAs, post-service review requests)
- Marketing (seasonal tune-up promos, membership upsells)
- Account notifications (payment receipts, membership renewal)
Each campaign has a monthly $1.50-$10 fee depending on type.
-
Approved message templates. You submit sample messages with the campaign. Carriers reject templates that look spammy or violate content rules (e.g., no SHAFT — Sex, Hate, Alcohol, Firearms, Tobacco).
-
Opt-in tracking. You have to prove every recipient consented. The carriers can audit your records.
-
STOP/HELP keyword compliance. Reply STOP must unsubscribe, reply HELP must return contact info. Both must work on every campaign.
Send unregistered SMS in 2026 and the carriers throttle to roughly 1 message/second per number, then start blocking entirely. Some shops have woken up to find Tuesday’s review-request campaign got 18% delivery because nobody registered the campaign.
What TCPA requires (the harder one)
TCPA is the legal teeth. Five rules to memorize:
1. Prior express written consent for marketing
To send any SMS or autodialed call for marketing purposes (tune-up specials, membership pitches, replacement promos), you need the recipient’s prior express written consent. Verbal consent at the time of service is not enough for marketing. The signature can be e-signature, a checked box on a web form, or a SMS opt-in keyword (“text JOIN to 555-555-5555”).
The consent language must be a “clear and conspicuous” disclosure stating:
- The recipient agrees to receive marketing SMS
- From a specific company (you, by name)
- That consent is not a condition of purchase
- That message and data rates may apply
The 2024 one-to-one consent update means a homeowner can only consent to receive marketing from one company per consent action. The old “agree to be contacted by us and our partners” lead-form trick is dead.
2. Service messages are different
Transactional / informational SMS (appointment confirmations, “tech is 15 minutes out,” ticket-paid receipts) does NOT require the same prior express written consent as marketing. Implied consent from doing business with you is fine. But you still need to honor STOP at any time and include identifying info.
3. STOP must be instant and persistent
If a homeowner texts STOP, you have to suppress them across every campaign immediately. Not 24 hours later. Not just from the one campaign. Across all SMS from your shop. The suppression is permanent unless they explicitly opt back in.
4. Quiet hours
You cannot send marketing SMS before 8am or after 9pm local time (recipient’s local time, not yours). Service SMS — appointment reminders, dispatch ETAs — has more latitude but should still respect quiet hours unless explicitly requested.
5. Identify yourself in every message
Every SMS must identify your shop by name and provide a way to opt out. The standard footer:
Reply STOP to opt out. Reply HELP for support.
Most CRMs auto-append this. Verify yours does.
What this looks like in practice for your shop
Day-of-service “tech is on the way” SMS: transactional. Implied consent. STOP must work. No special opt-in needed.
Post-service review request SMS: transactional/informational. Implied consent. STOP must work. Marketing message rules don’t apply because you’re not selling anything.
Spring tune-up promo SMS to past customers: marketing. Prior express written consent REQUIRED. Quiet hours apply. Marketing campaign registered with carriers.
Membership upsell SMS after service: marketing-adjacent. The safe play is to treat it as marketing and require opt-in. The argument for treating it as transactional is weak — you’re trying to sell them something.
“Hey we’re hiring techs” recruiting SMS: marketing. Requires written consent.
What the snapshot does for you
The snapshot ships with:
- A2P 10DLC brand and campaign registration as part of install. We run the TCR registration and pre-built campaigns for customer care, marketing, and account notifications.
- Pre-built opt-in flows for web forms, calculators, and inbound SMS. Every flow captures timestamped consent with the exact language above.
- STOP/HELP keyword handlers baked into every campaign at the workflow level.
- Suppression lists that propagate STOP across every workflow within 60 seconds.
- Quiet hours enforcement — marketing messages cannot send between 9pm and 8am recipient-local automatically.
- Audit log of every consent capture and every STOP for at least 5 years (the safe retention window for TCPA documentation).
- Approved message templates for each campaign type so you’re not getting rejected by the carriers.
You still want a compliance attorney review your specific use cases — every shop has at least one campaign that’s borderline. But the platform-level compliance is handled.
What this protects you from
- Class-action TCPA suits (most often filed by serial plaintiffs who collect texts looking for non-compliant senders).
- Per-message fines from the FCC.
- Carrier delivery throttling and outright blocking.
- The “homeowner files a complaint with the State AG” pathway, which has been an increasing problem in 2025-2026.
If you’re sending SMS without registration and without consent, you’re sitting on an unknown liability. Read the TCPA + 10DLC HVAC SMS compliance guide for the step-by-step setup.