Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The agreement states that customers are solely responsible for all use of Twilio services under their accounts and for all acts, omissions, and activities of their End Users, including End User compliance with the agreement, the Acceptable Use Policy, and applicable law.
This analysis describes what Twilio's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision places full legal responsibility for End User conduct on the customer, meaning Twilio may suspend services or assert indemnification claims based on End User behavior that the customer may not have directly authorized or been able to prevent.
The updated terms establish a different dispute resolution process for customers domiciled or registered in Mexico. Previously, Mexico was subject to the standard arbitration venue clause routing disputes to San Francisco, California. Under the revised agreement, Mexican customers must first engage in good faith negotiations with Twilio's senior representatives for 30 days; if unresolved, disputes proceed to binding arbitration under Centro de Arbitraje de México (CAM) rules, conducted in English in Mexico City before a sole arbitrator. The agreement also explicitly states that Mexican consumer protection law (Ley Federal de Protección al Consumidor) does not apply to the commercial relationship between the parties. Mexico-domiciled customers should review the updated dispute resolution procedures and understand that consumer protection law carve-out before continuing use.
View change record →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.
View change record →The updated terms now route Twilio service agreements for Mexico and Brazil customers to new regional entities rather than Twilio Inc., which may affect service delivery, dispute resolution venue, and applicable local law. The definition of Order Form was expanded to explicitly include self-service online purchases, clarifying that terms negotiated through Twilio's account interface carry the same contractual weight as traditional executed agreements. The terms also removed language stating that Twilio would not materially decrease overall service functionality, replacing it with a simpler statement that services may change over time, which narrows the operational commitment Twilio makes regarding service stability. You can review the separate agreements that now govern your use based on your regional location.
View change record →Under these terms, customers bear sole responsibility for all End User acts and omissions, including compliance with the Acceptable Use Policy and applicable law, which is the basis for both the suspension rights and the indemnification obligations asserted elsewhere in the agreement.
Cross-platform context
See how other platforms handle Customer Responsibility for End Users and similar clauses.
Compare across platforms →Monitoring
Twilio has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"You will: (a) be solely responsible for all use of the Services and Documentation under your account and the Customer Services; ... (d) be solely responsible for all acts, omissions, and activities of your End Users, including their compliance with this Agreement, the Twilio Acceptable Use Policy, the applicable Documentation, any applicable Order Form(s), and applicable law or regulation;Excerpt from Twilio's Terms of Service
(1) REGULATORY LANDSCAPE: The assignment of full End User responsibility to the customer is standard in communications platform agreements and aligns with the intermediary liability framework applicable to platform providers under U.S. law. However, the breadth of this responsibility may interact with sector-specific regulatory obligations in financial services, healthcare, or telecommunications depending on the nature of End User activity. (2) GOVERNANCE EXPOSURE: High. The sole responsibility for End User compliance creates operational exposure for customers with large or diverse End User populations, particularly where End Users may violate the Acceptable Use Policy or applicable law without the customer's knowledge. (3) JURISDICTION FLAGS: EU and UK customers should assess whether applicable intermediary liability law, including under the EU Digital Services Act, limits the extent to which platform terms can assign full End User responsibility to business customers. The interaction between this provision and GDPR controller/processor obligations may also require evaluation. (4) CONTRACT AND VENDOR IMPLICATIONS: Customers should ensure their own End User agreements impose obligations consistent with Twilio's Acceptable Use Policy and applicable law, and that they have adequate monitoring and enforcement mechanisms to detect and remediate End User violations. (5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should review the Twilio Acceptable Use Policy and Service and Country Specific Requirements to ensure End User agreements and onboarding processes adequately address the obligations flowed down from this provision. Customers operating in regulated sectors should assess whether additional End User screening or monitoring is required.
Full institutional analysis
Regulatory citations, enforcement risk, and due diligence action items.
Monitor: same-day alerts on the platforms you choose. Analyst: full institutional analysis.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision places full legal responsibility for End User conduct on the customer, meaning Twilio may suspend services or assert indemnification claims based on End User behavior that the customer may not have directly authorized or been able to prevent.
Under these terms, customers bear sole responsibility for all End User acts and omissions, including compliance with the Acceptable Use Policy and applicable law, which is the basis for both the suspension rights and the indemnification obligations asserted elsewhere in the agreement.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.