Managing deactivated and ported numbers

Complete guide covering deactivated phone number compliance requirements, porting issues, and step-by-step operational procedures for daily deactivation monitoring to maintain FCC compliance.

What is a deactivated phone number?

A deactivated phone number is one that a mobile operator has taken out of service for an end user, either because the end user switched operators or closed their account. Eventually, all deactivated numbers are recycled and activated for new subscribers.

This creates compliance risk: it is easy to mistakenly send a text message to a phone number that has been reassigned to an end user who has not opted into your program.

Timeline variance by carrier [#timeline-variance-by-carrier-what-is-a-deactivated-phone-number]

Mobile operators do not keep numbers inactive for the same amount of time:

• Fast reassignment: 2 days (AT&T, T-Mobile, Verizon)
• Standard reassignment: 2 to 5 days (most major carriers)
• Slow reassignment: 2 to 50 days (regional and smaller carriers)

Why deactivation monitoring matters

FCC compliance risk [#fcc-compliance-risk-why-deactivation-monitoring-matters]

The Federal Communications Commission (FCC) considers messages sent to reassigned numbers as spam and can impose serious fines for sending messages to users who have not opted in.

Compliance penalties:

• FCC fine: Up to $1,500 per message sent to a reassigned number
• Class-action lawsuit: Consumers can sue for TCPA violations
• Account suspension: Repeated violations can lead to account closure

This is why daily monitoring is imperative.

Example scenario [#example-scenario-why-deactivation-monitoring-matters]

A business has Jennifer's phone number and her explicit consent to receive SMS. Jennifer switches carriers and does not port her number, so her old number is deactivated. After 2 days (the AT&T deactivation period), AT&T reassigns her number to Marcus, a new subscriber who has never opted into the business's program.

If the business sends a message to that number, Marcus receives it, which is a message he never consented to. The FCC considers this spam regardless of Jennifer's original consent. The business faces a $1,500 fine per message.

Messaging restrictions for deactivated numbers

You can still:

• Reach out to the previous number owner using a different communication channel (email or another channel)
• Store deactivation information for operational purposes
• Flag the number for future attempts once it has been off the deactivation list for sufficient time

USA carriers providing deactivation reports

Infobip provides daily deactivation reports from USA carriers. The reports originate from mobile operators and contain phone numbers associated with deactivate and disconnect events.

All reports are available as previous day data through the Number Activation State API.

Implement daily deactivation monitoring

Step 1: Request API access [#step-1-request-api-access-implement-daily-deactivation-monitoring]

The Number Activation State API provides daily reports of numbers with activation status changes (deactivations, suspensions, reactivations). Access must be approved by your Account Manager.

Steps:

1. Contact your Infobip Account Manager
2. Request access to "Number Activation State API"
3. Infobip analyzes your business and traffic for compliance approval
4. Once approved, you will receive API credentials and Bearer token

Step 2: Retrieve deactivation reports daily [#step-2-retrieve-deactivation-reports-daily-implement-daily-deactivation-monitoring]

You must retrieve and process deactivation reports every single day. Use Infobip's Number Activation State API to get daily network reports of number status changes.

API endpoints:

• GET /number-activation-state/1/network-reports - Get list of available reports
• GET /number-activation-state/1/network-reports/{reportId} - Get report content with deactivated numbers

For complete API documentation including query parameters and response formats, see the Number Activation State API reference.

Implementation steps:

1. Set up a scheduled process to run daily (recommended: 2 AM UTC)
2. Query the reports endpoint to retrieve available reports
3. Identify the report for the previous day
4. Call the report content endpoint with the report ID
5. Parse the response for all numbers marked as deactivated
6. Remove deactivated numbers from your recipient lists
7. Log the process execution with timestamp and results

Step 3: Process deactivation report [#step-3-process-deactivation-report-implement-daily-deactivation-monitoring]

When you receive deactivation notices:

1. Immediately identify which numbers are deactivated
2. Extract phone numbers from the deactivation report
3. Flag in your system as "do not message"
4. Update recipient database to exclude flagged numbers
5. Document date flagged for audit trail and compliance

Step 4: Remove from all lists [#step-4-remove-from-all-lists-implement-daily-deactivation-monitoring]

Deactivated numbers must be removed from ALL messaging lists and databases:

1. Query all recipient lists for matching deactivated numbers
2. Remove from active campaigns (do not send to these numbers)
3. Delete from contact databases and phone books
4. Update suppression lists if you maintain them
5. Notify Infobip support if number was recently sending at high volume

Why all lists? A number may be in multiple campaigns, databases, or systems. You must remove it everywhere to prevent accidental messaging.

Step 5: Contact previous owners (optional) [#step-5-contact-previous-owners-optional-implement-daily-deactivation-monitoring]

If you have contact information for previous number owners:

1. Send email: "We noticed we have not heard from you in a while..."
2. Request their updated phone number
3. Request re-opt-in confirmation (TCPA requires annual re-consent)
4. If they reply with new number, add with fresh opt-in consent

Benefits:

• Recover lost customers
• Re-establish legal consent (required annually)
• Improve list quality
• Reduce FCC violation risk

Step 6: Maintain audit trail [#step-6-maintain-audit-trail-implement-daily-deactivation-monitoring]

For compliance and legal protection:

1. Log every API call with timestamp and date requested
2. Document deactivated numbers (which numbers, when flagged)
3. Record removal actions (which lists, when removed)
4. Track any issues (missed numbers, processing errors)
5. Retain logs for 3 or more years (legal requirement for FCC disputes)

Troubleshooting deactivated and ported numbers

Issue: Messages failing to deliver after carrier switch (ported numbers) [#issue-messages-failing-to-deliver-after-carrier-switch-ported-numbers-troubleshooting-deactivated-and-ported-numbers]

When an end user switches mobile operators and ports their existing phone number, the number appears in the original operator's deactivation list but remains active on the new operator's network. This can cause delivery failures if your system tries to route through the original operator.

What to do:

1. When you receive delivery failures for a number, perform a number lookup to determine the current operator
2. If the operator has changed, update your records with the new carrier information
3. Resend the message with the correct operator specified
4. Store the current operator information for future sends to that number
5. Periodically refresh operator lookups for frequently messaged numbers to catch subsequent ports

Learn more

USA SMS compliance requirements: CTIA standards and carrier compliance
Number Activation State API: Technical documentation for retrieving deactivation reports