Memorandum Circular 12-12-2023 is a telecommunications regulation issued by the National Telecommunications Commission (NTC) that mandates real-time text-scrubbing to combat SMS scams, with daily fines of PHP 50,000 for non-compliant telecommunications providers.
Issued in December 2023, this memorandum circular strengthens the NTC's anti-text scam campaign by requiring Globe Telecom, Smart Communications, and DITO Telecommunity to implement automated filtering systems that detect and block fraudulent messages before they reach subscribers.
Key Provisions
- Real-time text-scrubbing requirement: Telecommunications companies must deploy systems that scan and filter SMS messages in real-time for scam indicators
- URL blocking mandate: All messages containing domains, URLs, or URL shortening services (e.g., bit.ly, tinyurl) associated with text scams must be blocked or deactivated
- Clickable link restrictions: Globe blocks all SMS messages containing clickable URL links; Smart blocks URL shorteners specifically
- Scam keyword detection: Carriers must filter messages containing keywords commonly used in phishing, smishing, and fraudulent schemes
- Daily penalty: Non-compliant telecommunications companies face PHP 50,000 in fines per day of violation
Who is Affected?
This memorandum circular directly impacts:
- Telecommunications providers: Globe, Smart, and DITO must implement and maintain text-scrubbing infrastructure
- SMS aggregators and gateways: Third-party messaging providers serving Philippine numbers must comply with content filtering requirements
- Real estate brokerages: Companies using SMS for lead generation, appointment scheduling, or notification systems must adapt messaging strategies
- Marketing teams: Campaigns relying on URL links in SMS messages require pre-approval or alternative delivery methods
- Property developers: Bulk SMS campaigns for project launches face stricter content review
Penalties
| Violation | Penalty |
|---|---|
| Failure to implement text-scrubbing systems | PHP 50,000/day |
| Non-compliance with URL blocking requirements | PHP 50,000/day |
| Continued operation with unregistered sender IDs | Message blocking |
Penalties accumulate daily until the telecommunications provider demonstrates compliance.
Relevance to Philippine Real Estate
M.C. 12-12-2023 significantly affects how you communicate with clients and prospects through SMS. Here's what it means for your brokerage operations:
URL restrictions in messages: If you previously included property listing links in SMS blasts, you must now use alternative approaches:
- Direct clients to search your website by name instead of clickable links
- Use registered SMS Sender IDs with pre-approved banking or property-related URLs
- Send links through Viber campaigns or email instead of SMS
Content filtering impacts: Messages containing certain keywords may be blocked. Avoid phrases commonly associated with scams, such as "CLAIM NOW," "FREE," or "WINNER."
Sender ID registration becomes critical: Unregistered alphanumeric sender IDs face increased scrutiny. Work with your SMS provider to register your brokerage name through the NTC. The provisioning process takes 2-4 weeks.
Marketing form adjustments: Your marketing form management strategy should shift confirmation messages away from URL-heavy content. Instead of sending "Click here to confirm: [link]," send "Reply YES to confirm your site visit."
To maintain effective client communication while complying with M.C. 12-12-2023, we recommend:
- Registering your SMS Sender ID before launching campaigns
- Using the notification center to coordinate multi-channel messaging
- Implementing abandoned lead notifications through compliant channels
- Monitoring delivery rates across Globe, Smart, and DITO networks through your CRM analytics
Related Terms
- National Telecommunications Commission (NTC)
- SMS Sender ID
- Notification System
- Data Privacy Act
- Data Privacy Compliance
References
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