Provision record
Twilio · Twilio Terms of Service · View original document ↗

Customer Responsibility for End Users

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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium May 9, 2026

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 →
Medium Apr 19, 2026

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.

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Medium Apr 10, 2026

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 →

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Change history

modified Jul 17, 2026

Changed from general responsibility to enumerated 'will' obligations; added explicit requirement for End User compliance with Acceptable Use Policy, Documentation, and applicable law; structured as multi-part customer warranty rather than liability carve-out.

View full change record →

Consumer impact (what this means for users)

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.

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(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.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Twilio Terms of Service
Entity
Twilio
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014982
Document ID
CA-D-00251
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
563695446de6e1fe2b002e78749cbeb0f72c3c272628f2d9b6a79593b74ede20
Analysis generated
July 9, 2026 06:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Terms of Service
Record ID: CA-P-014982
Captured: 2026-07-09 06:51:38 UTC
SHA-256: 563695446de6e1fe…
URL: https://conductatlas.com/platform/twilio/twilio-terms-of-service/provision/CA-P-014982/customer-responsibility-for-end-users/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Twilio's Customer Responsibility for End Users clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.