Twilio updated its Terms of Service on April 19, 2026 to expand the geographic scope of service entities, add new Mexico and Brazil-specific entities to the agreement, and clarify how orders can be placed through online self-service workflows in addition to traditional ordering documents. The agreement also removed a prior assurance that Twilio would not materially decrease overall service functionality, replacing it with a simpler statement that services may change over time. Additionally, Twilio added a recommendation that customers download and save a PDF copy of the terms.
The updated terms establish two new regional service entities: CISA Telecomunicaciones for Mexico and Teravoz Telecom for Brazil, meaning customers in those jurisdictions will contract with the local entity rather than Twilio Inc. The agreement now permits orders to be placed through Twilio's online self-service purchasing workflow in addition to traditional written order forms, streamlining how purchase terms can be documented. The updated language also removes the prior commitment that Twilio will not materially decrease overall service functionality, replacing it with a general statement that services may change over time without specific protections on functionality levels.
The addition of Mexico and Brazil service entities creates distinct legal contracting relationships with regional companies, potentially affecting dispute venue, applicable law, and regulatory compliance for customers in those jurisdictions. The removal of the functionality protection clause broadens Twilio's contractual authority to modify service features without the prior constraint that changes be non-material to overall functionality, shifting risk to customers who may have relied on that commitment for service stability planning.
→ If you operate in Mexico or Brazil, verify which Twilio entity is named in your current agreement and confirm whether regional data residency, consumer protection, or telecommunications regulations apply.
→ Download and save a PDF copy of the updated Terms of Service as Twilio recommends, to preserve a record of the version you accepted.
→ If you operate in Mexico or Brazil and do not verify which Twilio entity you contract with, disputes or compliance obligations may be governed by the regional entity's jurisdiction and applicable law.
→ If you have documented service stability or uptime commitments to your own customers, the removal of Twilio's functionality protection language means Twilio may modify service features without the prior contractual constraint, potentially affecting your ability to meet those downstream commitments.
ConductAtlas has recorded 2 material changes to this document (since April 2026).
2 of Twilio's significant changes have been classified as negative for consumers.
Added Mexico and Brazil as separate jurisdictions with dedicated regional legal entities, establishing country-specific contracting relationships that may carry distinct liability, dispute resolution, and regulatory compliance implications.
Expanded definition of Order Form to include online self-service ordering through Twilio's account portal, in addition to traditional written ordering documents between parties.
Removed prior language prohibiting material decreases in service functionality; updated language now states services 'may change over time' without specific functional protections.
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
If you operate in Mexico or Brazil, you are now contracting with a local Twilio company instead of the Delaware corporation, which may affect where disputes are resolved and which country's laws apply.
Twilio no longer commits contractually to maintain service functionality levels; the agreement now states services may change over time without specific protections on what changes are permissible.
Twilio introduced regional legal entities for Mexico and Brazil, creating country-specific contracting relationships and potential implications for liability, dispute resolution venue, and regulatory compliance in those jurisdictions. The removal of language prohibiting material functionality decreases expands Twilio's contractual discretion to modify service features. The addition of self-service online ordering as a valid order mechanism may create documentation and contract formation questions for enterprise customers accustomed to formal purchase orders. Organizations with customers in Mexico or Brazil should verify which entity their agreements reference and whether regional data residency, labor law, or regulatory requirements apply.
GDPR, CCPA, Mexico Federal Consumer Protection Law (LFCC), Brazil Consumer Protection Code (Código de Defesa do Consumidor), local telecommunications regulations in Mexico and Brazil
Full compliance analysis
Obligation analysis, escalation trigger, board language, and recommended action.
Watcher: regulatory citations + obligations. Professional: full compliance memo.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001101.
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