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The agreement authorizes Twilio to suspend all services upon written notice based on its good-faith determination that any of five specified conditions are met, including AUP violations, fraudulent traffic, regulatory prohibition, security threats, or inaccurate account information. Customers remain liable for fees during any suspension period.
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 creates a unilateral suspension right exercisable on Twilio's good-faith determination, including for conditions such as inaccurate account information that may not require customer fault. Fee obligations continue during suspension, creating potential financial exposure for customers whose services are suspended.
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 this clause, Twilio may suspend all services to all of a customer's accounts upon written notice based on its own good-faith determination, and the agreement states that customers remain responsible for fees during any suspension period.
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"Twilio may suspend the Services upon written notice to you if Twilio, in good faith, determines: (a) that you or your End Users materially breach (or Twilio, in good faith, believes that you or your End Users have materially breached) the Twilio Acceptable Use Policy; (b) there is an unusual and material spike or increase in your use of the Services and that such traffic or use is fraudulent or materially and negatively impacting the operating capability of the Services; (c) that its provision of the Services is prohibited by applicable law or regulation; (d) there is any use of the Services by you or your End Users that threatens the security, integrity, or availability of the Services; or (e) that information in your account is untrue, inaccurate, or incomplete. You remain responsible for the Fees.Excerpt from Twilio's Terms of Service
(1) REGULATORY LANDSCAPE: Unilateral suspension clauses in communications platform agreements are standard in the industry but engage telecommunications provider obligations and, where applicable, telecommunications regulatory frameworks. The retention of fee obligations during suspension may interact with applicable consumer protection law in EU and UK jurisdictions. FTC authority over unfair commercial practices is relevant where suspension is exercised without adequate notice or basis. (2) GOVERNANCE EXPOSURE: High. The suspension trigger includes Twilio's good-faith belief of an AUP violation by End Users, meaning customer services may be suspended based on End User conduct outside the customer's direct control. The continued fee obligation during suspension creates financial exposure proportional to the customer's monthly spend. (3) JURISDICTION FLAGS: EU and UK customers should evaluate whether applicable law limits the unilateral suspension rights asserted in this clause, including whether advance notice requirements under the European Electronic Communications Code or national telecommunications law apply. The agreement separately references European Electronic Communications Code Disclosures, suggesting Twilio has acknowledged this regulatory interaction. (4) VENDOR AND CONTRACT IMPLICATIONS: Enterprise customers integrating Twilio as a core communications dependency should assess business continuity and redundancy planning given the breadth of the suspension triggers. Customers with downstream service level commitments to their own end users face potential liability exposure if Twilio suspension affects their ability to deliver contracted services. (5) COMPLIANCE CONSIDERATIONS: Legal and operations teams should review their End User agreements and monitoring practices to ensure they can detect and remediate AUP violations promptly. Customers should also ensure account registration information is accurate and kept current, as inaccurate or incomplete account information is an independent suspension trigger under the agreement.
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This provision creates a unilateral suspension right exercisable on Twilio's good-faith determination, including for conditions such as inaccurate account information that may not require customer fault. Fee obligations continue during suspension, creating potential financial exposure for customers whose services are suspended.
Under this clause, Twilio may suspend all services to all of a customer's accounts upon written notice based on its own good-faith determination, and the agreement states that customers remain responsible for fees during any suspension period.
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