ANATEL’s Regulatory Assessment of the A2P SMS Market

Anatel completed a dedicated market assessment for enterprise A2P bulk SMS while revising the PGMC General Plan for Competition Objectives. Although the A2P‑SMS market generates nearly USD 500 million in annual revenue, with OTP verification and transaction notifications driving new growth, the regulator concluded A2P‑SMS does not qualify as a “relevant market”. It will not be subject to dedicated ex-ante regulation, and no mandatory special market entry or price controls will be imposed.

The regulatory model shifts to complaint-driven passive ex-post supervision. There will be no proactive market intervention under normal circumstances; case investigations are triggered only after receiving complaints or reports from market players. The authority will re-evaluate the need for stronger intervention in the future. The report acknowledges regulatory and technical access barriers on mobile operators’ side, yet rules these barriers do not create material competition distortions.

For Brazilian SMS aggregators, this finding means no new A2P-specific entry or pricing rules in the short term. Negotiation still exists over operators’ commercial terms and gateway thresholds at the wholesale level. If aggregators face gateway blocking or discriminatory treatment, they may only file complaints with Anatel under PGMC Resolution No.783. Aggregators must also continue complying with general SMS compliance rules including Resolution No.765 and anti-spoofing rulings.