Twilio · Twilio Terms of Service

Class Action Waiver

High severity
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What it is

You cannot join or start a class action lawsuit or class arbitration against Twilio — every dispute must be handled individually.

Change history

added May 1, 2026

Explicitly separates class action waiver from mandatory arbitration clause and adds jury trial waiver, significantly limiting customers' procedural rights to aggregate disputes.

View full change record →

Consumer impact (what this means for users)

This waiver means that even if many businesses experience the same harm from Twilio — such as a billing error or service failure — each must pursue claims individually, making small-value claims economically nonviable and reducing Twilio's accountability at scale.

Cross-platform context

See how other platforms handle Class Action Waiver and similar clauses.

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Why it matters (compliance & risk perspective)

Class action waivers are particularly significant for businesses that have suffered widespread but individually small harms — such as overbilling or service outages affecting thousands of customers — because they make collective redress economically impractical.

View original clause language
To the fullest extent permitted by applicable law, you and Twilio each waive the right to a trial by jury and to participate in a class action, class arbitration, or representative proceeding. This waiver applies to all disputes covered by this arbitration agreement.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: Class action waivers in arbitration agreements are generally enforceable under AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011) and Epic Systems Corp. v. Lewis, 584 U.S. 497 (2018). However, California's McGill Rule (McGill v. Citibank, N.A., 2 Cal.5th 945 (2017)) limits waivers of public injunctive relief under Cal. Bus. & Prof. Code §17200. NLRA protections for concerted activity may also create carve-outs in certain employment-adjacent contexts. (2)

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Applicable agencies

  • FTC
    The FTC monitors class action waivers for potentially unfair or deceptive practices that harm businesses and consumers who lack practical recourse for small individual claims.
    File a complaint →
  • State AG
    State attorneys general, particularly in California, have enforcement authority over class action waiver enforceability under state consumer protection and unfair competition laws.
    File a complaint →

Provision details

Document information
Document
Twilio Terms of Service
Entity
Twilio
Document last updated
April 29, 2026
Tracking information
First tracked
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003583
Document ID
CA-D-00251
Evidence Provenance
Source URL
Wayback Machine
SHA-256
dd88fb1d746956ef5d8534a318f62f673d24ac97e4d73bfca637a8e75c574245
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Twilio | Document: Twilio Terms of Service | Record: CA-P-003583
Captured: 2026-04-27 14:51:24 UTC | SHA-256: dd88fb1d746956ef…
URL: https://conductatlas.com/platform/twilio/twilio-terms-of-service/class-action-waiver/
Accessed: May 2, 2026
Classification
Severity
High
Categories

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