WhatsApp Business and customer relations the conversation leaves the site

I

Messaging apps have become the space where people talk to each other

WhatsApp has more than 3 billion monthly active users, according to Mark Zuckerberg during the presentation of Meta’s first-quarter 2025 results¹. Messenger is used every month by more than a billion people, and Mark Zuckerberg adds that business messaging “should be the next pillar” of Meta’s business¹.

In France, the trend is the same. According to the 2026 edition of the Digital Barometer (Baromètre du numérique), carried out by Crédoc for Arcep, Arcom, the CGE and the ANCT among 4,145 people surveyed from June 5 to 21, 2025, 86% of the population aged 12 and over uses instant messaging apps². Among these users, 87% use WhatsApp, 76% Messenger and 60% Instagram. 82% use more than one messaging app, and 66% say they chose the ones their contacts use².

That last figure matters for a customer relations department. People don’t choose a messaging app for a brand, but for the people around them. The contact channel is no longer a place the company builds and invites its customers into: it’s a place they already live in.

II

Asynchronous becomes the norm of the customer conversation

On the WhatsApp Business Platform, each customer message opens a 24-hour “customer service window,” and each new customer message restarts that clock³. While the window is open, the business can reply freely. Once it has closed, it can only reach out again using message templates submitted in advance³. Messenger and Instagram work on a similar principle: a standard messaging window that lasts 24 hours for most user actions¹².

These rules reflect a change in behavior. A call or an on-site chat assumes both parties are present at the same time. A messaging thread doesn’t. The customer asks their question on the train and sends the photo of the damaged parcel in the evening. The conversation doesn’t end when the browser closes: it stays in the thread, with its history, in front of the customer.

Quality is then also measured by continuity. A customer who comes back three days later in the same thread expects the company to remember what they said, and doesn’t understand being asked again for an order number that appears a few messages above.

III

WhatsApp Business Platform: the rules in force in October 2026

The WhatsApp Business Platform is the interface through which a company connects its own systems to WhatsApp⁸, whether that’s an AI agent, a ticketing tool or an ordering system.

Four message categories, billing per message

Since July 1, 2025, Meta bills the platform per message rather than per conversation⁴. Messages sent by the business fall into four main categories³⁵:

As of July 1, 2025, utility messages sent in reply to the customer within an open service window became free; service conversations had already been free since November 1, 2024⁴. As of October 1, 2026, Meta resumed billing for these previously free messages⁴. Utility messages sent within the service window are now billed at the standard rate. For service messages, each business phone number gets a free tier of 1,000 delivered messages per month, non-cumulative, beyond which they are billed³⁴.

Two other items matter for a budget. Meta can only change its rates on the first day of each quarter, that is at most four times a year³. And when a customer writes in after a “Click to WhatsApp” ad, a so-called free entry point window can stay open for up to 7 days, during which marketing, utility, authentication and service messages are not billed³.

Finally, since July 1, 2026, Meta’s pricing includes a fifth category: free-form messages produced by its own agent platform, Meta Business Agent Platform, billed by the volume of tokens consumed³. Meta is therefore both the operator of the channel and a provider of agents on that channel.

Consent and honoring opt-out requests

Under the WhatsApp Business Messaging Policy, updated on September 23, 2026, a business may only contact a person on WhatsApp if that person has given it their mobile phone number or username, and if it has received their consent (opt-in) confirming they want to receive messages⁶. The same policy recommends collecting consent by message category, explaining how to unsubscribe from each category, and requires honoring any request to stop, whether made on WhatsApp or elsewhere⁶.

French law adds its own requirement. The CNIL reminds businesses that commercial prospecting by electronic means to individuals requires their prior consent, under Article L34-5 of the French Postal and Electronic Communications Code, with an exception for similar products or services offered to an existing customer¹⁰. The CNIL notably cites email and SMS-MMS, in a non-exhaustive list: the prudent approach is to treat a WhatsApp marketing message with the same rigor. The GDPR applies to all exchanges, notably the information given to individuals (Article 13), data minimization and the limitation of retention periods (Article 5)¹⁸.

Automation and human handoff

WhatsApp’s policy allows automated replies during the 24-hour window, on one condition: having “quick, clear and direct” escalation paths to a human⁶. Handing off to an advisor within the conversation is among the options cited, along with phone, email or a contact form. Since August 2, 2026, the AI Act adds a transparency obligation: AI systems must be designed to inform people that they are interacting directly with an AI¹¹.

IV

Meta’s policy on general-purpose AI assistants

In October 2025, Meta announced a new policy prohibiting AI providers from using the WhatsApp Business Solution when AI is the primary service offered⁷. According to the European Commission, the terms update applied from October 15, 2025 to providers new to WhatsApp, and from January 15, 2026 to those already on it⁷. The Commission specifies that businesses remain free to use AI tools for incidental or support functions, such as automated customer service offered through WhatsApp⁷.

The Commission opened a competition investigation on December 4, 2025, covering the European Economic Area except Italy, where the national authority was running its own proceeding⁷. On June 9, 2026, it imposed interim measures⁸. It notes that Meta had readmitted third-party general-purpose AI assistants on March 4, 2026, but in return for a fee that it considers, prima facie, equivalent in practice to the ban. It orders Meta to restore their API access on the terms that applied before October 15, 2025, notably free of charge, until its final decision⁸. Meta appealed to the General Court of the European Union in August 2026, according to the firm advising it⁹, and the investigation on the merits was still ongoing at the time of the June 9 decision⁸.

For a company deploying a customer service AI agent, this case doesn’t change the framework: that use falls under the support functions the policy leaves open⁷. It does, however, serve as a reminder that the channel belongs to an operator who sets its own terms and prices. A solid messaging strategy therefore doesn’t depend on a single channel.

V

The other channels: Instagram, Messenger, RCS, Apple

Instagram and Messenger

Instagram and Messenger go through Meta’s developer tools, with a standard 24-hour messaging window for most user actions, extended up to 7 days after a first message following a “Click-to-Messenger” or “Click-to-Direct” ad¹². The “Human Agent” tag lets an advisor reply manually for 7 days. Meta also asks that automated experiences signal that they are an automated service where the law requires it, and recommends it in other cases¹².

RCS: the native messaging app on smartphones

RCS (Rich Communication Services) is a messaging standard that brings, inside the phone’s native app, richer media and more reliable group conversations than SMS and MMS. Apple built it into Messages with iOS 18, in September 2024, for exchanges with people who don’t use an Apple device¹³. On iPhone, RCS requires a compatible carrier, its availability varies by region and carrier, and the user can turn off the “RCS Business Messages” sent by businesses¹⁴. Google, which offers “RCS for Business,” specifies that Apple itself chooses the carriers with which it launches business RCS messaging on iOS¹⁵. The strength of RCS is that it requires no additional app; its coverage has to be checked market by market.

Apple Messages for Business

With Apple Messages for Business, the customer opens the conversation, from a button placed on a website, an app, a QR code or an Apple Maps listing¹⁶. The business can then write to them proactively, only in their direct interest, such as an order update. The service goes through a messaging provider approved by Apple, which may charge for its services; Apple does not charge for it¹⁶.

VI

The DMA paves the way for messaging interoperability

Article 7 of the Digital Markets Act (Regulation (EU) 2022/1925) requires gatekeepers to make their messaging services interoperable with those of other providers that request it. Meta was designated on September 6, 2023 for WhatsApp and Messenger¹⁷. The timeline is staggered: text messages, images, files and voice messages between two users first, with a deadline of March 7, 2024 for WhatsApp and September 7, 2024 for Messenger; group conversations within two years of designation, that is September 7, 2025; voice and video calls within four years, that is September 7, 2027¹⁷. According to the Commission, the first two third-party messaging apps interoperable with WhatsApp launched in November 2025¹⁷. Article 7(3) requires preserving the level of security, including end-to-end encryption, in interoperable services¹⁸.

These obligations target exchanges between users, not business messaging. Our reading is that they confirm a trajectory: in Europe, messaging is treated as infrastructure whose access the regulator is seeking to open.

VII

One customer memory across the website, messaging and voice

Each channel described above imposes its own rules: a 24-hour window on WhatsApp and Messenger³¹², a conversation that only the customer can open at Apple¹⁶, RCS business messages that the user can turn off on iPhone¹⁴. Yet the same customer may start on the website, continue on WhatsApp, then call customer service. If each channel is served by a separate tool, the customer runs into as many separate memories as there are touchpoints.

Our analysis is that value is shifting from the channel to continuity between channels. A good messaging exchange requires the AI agent or advisor to know what was said on the website the day before and which appointment was booked by phone. That calls for a single source of customer context and rules of conduct written once, adapted to the constraints of each channel. It is also what preserves your freedom: when customer memory lives in your own system, a policy change at an operator is handled as a setting, not a rebuild.

VIII

The storefront and the counter become a single thread

According to the Digital Barometer (Baromètre du numérique), 66% of messaging users chose the apps their contacts use². What follows is a working hypothesis, supported by these usage patterns. Digital customer experience has long been organized around a place, the website, that you visit and then leave. Messaging reverses this relationship: it is the company that takes its place in a thread that is already open, between a family conversation and a group of friends.

In this thread, the storefront and the counter meet. The same exchange can bring together advice on a size, a delivery update, an appointment booking and a complaint backed by a photo, over several weeks. The thread becomes the customer file as the customer sees it, and calls to be handled as an ongoing relationship rather than a succession of tickets.

IX

What this means for your organization

WhatsApp’s policy requires explicit consent and an escalation path to a human⁶. Beyond that, opening a messaging channel without degrading quality calls for a few decisions up front.

Start with service journeys, not broadcasts. The safest first use cases are those where the customer writes first: order tracking, booking or changing an appointment, a pre-purchase question, a complaint. Marketing campaigns come later, once consents are in place.

Collect consent by category. From the sign-up form onward, distinguish utility messages (tracking, reminders) from marketing messages, as WhatsApp’s policy recommends⁶. Document the date, channel and wording of the consent, and handle opt-outs by category, even when they arrive through another channel.

Design for asynchronous. Have the message templates needed to reach out again outside the 24-hour window approved in advance, and organize schedules so that evening and weekend requests are answered within the window. Measure resolution time over the life of the thread, not just first response time.

Guarantee human handoff with context. Handoff is only valuable if the advisor receives the history and the reason for the request, so the customer has nothing to repeat. Define in advance the situations that trigger it: dispute, strong emotion, out-of-scope request, a customer who asks for it.

Disclose the AI from the first message. Since August 2, 2026, AI systems must inform people that they are interacting with an AI¹¹. A simple sentence at the start of the conversation sets the frame.

Unify customer memory. Before adding a channel, check that its history will feed the same customer record as the website and the phone.

Manage the budget quarterly. With billing resuming for service messages and utility messages on October 1, 2026, estimate your volumes by category and by number, and revisit these assumptions at the start of each quarter, the only possible dates for a pricing change at Meta³⁴.

Track quality conversation by conversation. Regularly review a sample of threads, spot unresolved requests and adjust the AI agent’s rules accordingly.

X

Where QLOA stands

XI

Frequently asked questions

How much does the WhatsApp Business API cost a business in 2026?

Since July 1, 2025, Meta bills each message by its category: marketing, utility, authentication or service, plus, since July 1, 2026, the Meta Business Agent category, billed per token. Since October 1, 2026, utility messages sent within the 24-hour window are billed, and service messages are billed beyond 1,000 free messages per month per number. Rates vary by country and can only change on the first day of each quarter.

What is the 24-hour window on WhatsApp Business?

It is the period that opens each time a customer writes to or calls a business on WhatsApp. For 24 hours, restarted with each new customer message, the business can reply with free-form messages. Once the window has closed, it can only reach out again with pre-approved message templates, which fall under the marketing, utility or authentication categories.

Can you use an AI agent on WhatsApp for customer service?

Yes. The policy Meta announced in October 2025 targets providers whose AI is the primary service offered, such as general-purpose assistants. According to the European Commission, businesses can continue to use AI for support functions, such as automated customer service. WhatsApp’s policy does, however, require a clear escalation path to a human, and the AI Act requires telling the customer they are talking to an AI.

Do you need consent to send WhatsApp messages to your customers?

Yes. WhatsApp’s policy requires that the person has provided their number or username and agreed to receive messages from the business. It recommends separate consent for each message category. In France, electronic prospecting of individuals also requires prior consent according to the CNIL, with an exception for similar products offered to an existing customer.

Can RCS replace WhatsApp for customer relations?

RCS is built into the phone’s native messaging app, with no installation, including on iPhone since iOS 18. Its availability does depend on carriers and countries, however, and the user can turn off RCS business messages on iPhone. In October 2026, it complements WhatsApp more than it replaces it. The right approach is to check coverage in your markets and serve both channels with the same customer memory.

XII

Sources

1. 1

   Meta Platforms, “First Quarter 2025 Results Conference Call” (transcript), April 30, 2025. s21.q4cdn.com

2. 2

   Crédoc for Arcep, Arcom, the CGE and the ANCT, “Baromètre du numérique, 2026 edition: equipment and usage” (fieldwork June 5 to 21, 2025), 2026. credoc.fr

3. 3

   Meta for Developers, “Pricing on the WhatsApp Business Platform,” accessed October 23, 2026. developers.facebook.com

4. 4

   Meta for Developers, “Pricing updates on the WhatsApp Business Platform,” accessed October 23, 2026. developers.facebook.com

5. 5

   Meta for Developers, “Template categorization,” accessed October 23, 2026. developers.facebook.com

6. 6

   WhatsApp, “WhatsApp Business Messaging Policy,” updated September 23, 2026. whatsappbusiness.com

7. 7

   European Commission, “Commission opens antitrust investigation into Meta’s new policy regarding AI providers’ access to WhatsApp,” IP/25/2896, December 4, 2025. ec.europa.eu

8. 8

   European Commission, “Commission imposes interim measures on Meta to preserve free access to WhatsApp for rival AI assistants,” IP/26/1276, June 9, 2026. ec.europa.eu

9. 9

   Slaughter and May, “Meta on its appeal against the European Commission’s WhatsApp interim measures decision,” August 25, 2026. slaughterandmay.com

10. 10

    CNIL, “Commercial prospecting by email, SMS-MMS and automated calling”, updated June 10, 2026. cnil.fr

11. 11

    European Commission, “Commission publishes guidelines on transparency obligations for providers and deployers of certain AI systems,” July 20, 2026. digital-strategy.ec.europa.eu

12. 12

    Meta for Developers, “Messenger Platform Policy Overview,” accessed October 23, 2026. developers.facebook.com

13. 13

    Apple, “iOS 18 is available today, making iPhone more personal and capable than ever,” September 16, 2024. apple.com

14. 14

    Apple Support, “Turn on RCS messaging on your iPhone,” May 11, 2026. support.apple.com

15. 15

    Google for Developers, “RCS for Business troubleshooting guide,” updated May 12, 2026. developers.google.com

16. 16

    Apple, “Apple Messages for Business Frequently Asked Questions,” accessed October 23, 2026. register.apple.com

17. 17

    European Commission, Digital Markets Act, “Messaging Interoperability,” accessed October 23, 2026. digital-markets-act.ec.europa.eu

18. 18

    European Commission and European Data Protection Board, “Joint Guidelines on the interplay between the DMA and the GDPR” (public consultation version), October 2025; Regulation (EU) 2016/679 (GDPR), Articles 5 and 13. https://www.edpb.europa.eu/system/files/2025-10/joint_com-edpb_gls_interplay_dma_gdpr_for_public_consultation_en.pdf; eur-lex.europa.eu