A New TCPA Risk: Caller ID Requirements for Marketing Texts?

A developing line of cases is pushing liability under the Telephone Consumer Protection Act (TCPA) into an unexpected place: requiring caller ID in marketing texts.

That idea first took hold about a year ago in Dobronski v. SelectQuote Ins. Servs., where the court reversed itself and concluded that caller ID regulations fall under a part of the TCPA that allows a private right of action. That ruling allowed the plaintiff to proceed and marked a departure from earlier decisions that had rejected similar claims.

Now, a second court has gone further. In Novia v. Mobiz, Inc., No. 25-CV-11036-AK, 2026 Lexis 135648 (D. Mass. Mar. 17, 2026), a Massachusetts federal court allowed a TCPA claim based on alleged caller ID deficiencies in telemarketing texts to proceed past the pleading stage. The court reasoned that the caller ID regulation, 47 C.F.R. § 64.1601(e), was issued under 47 U.S.C. § 227(c)—which provides a private right of action—and therefore may be privately enforced.

The decision applies that framework in the context of texts, without squarely resolving whether a text constitutes a “call” under the regulation or statute. Instead, the court treated the claim as plausible at the motion to dismiss stage, leaving those interpretive questions for later stages of the case.

With two courts now reaching similar conclusions on the private-right-of-action issue, what once appeared to be an outlier is beginning to take shape as a trend, but that conclusion is far from settled. The regulation applies to “telephone calls,” and a text is not clearly a call. Carriers also do not transmit traditional caller ID data with texts, raising the question whether the rule can be applied as written.

Furthermore, the regulation itself dates back to 2003, before modern texting and before later statutory changes addressing caller ID. There is also an enforcement issue. If the rule falls under a different section of the statute—such as 47 U.S.C. § 227(d), which does not provide a private right of action—it may not support private lawsuits at all, a position several earlier courts have adopted.

Even so, courts are beginning to move past those arguments at the pleading stage. Claims based on missing or incomplete identifying information in text campaigns are surviving early challenges. In Novia, for example, allegations that texts lacked a clear name and a working contact number were sufficient to state a claim, even where a link or partial branding was included.

The result is a mismatch between interpretation and reality. But courts are not waiting for that tension to be resolved. They are letting these cases proceed anyway. For now, that means risk is being defined less by how texts actually function and more by how courts are choosing to apply decades-old rules to it.