{
  "id": "BRD-160",
  "slug": "brd-160",
  "title": "Register the message sender, not the agency or platform",
  "statement": "The brand must be the legal entity whose messages are sent — never the agency, ISV, reseller, or software platform acting on its behalf.",
  "rationale": "Consent runs to a specific sender, so the brand on the registration must be the business the consumer agreed to hear from. Registering the agency or platform instead breaks that chain and is the highest-frequency brand rejection in the corpus — 10 separate sources across 11 authorities call it out.",
  "layer": "BRAND",
  "layerSlug": "brand",
  "object": "brand.company_name",
  "severity": "BLOCKING",
  "detectability": [
    "HUMAN",
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "TCR",
    "Twilio",
    "Telnyx",
    "Bandwidth",
    "AWS",
    "T-Mobile",
    "CTIA"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Register the brand under the legal entity that owns the customer relationship and whose name appears in the messages. If you are an agency or platform registering on behalf of a client, the client is the brand — register them, with their EIN and their website, and add yourself as the CSP rather than the brand.",
  "example": "Brand: Acme Coffee Co, LLC (the business texting its own customers) — not \"Northstar Marketing Group\" (the agency running the campaign).",
  "notes": "Highest-frequency brand rejection in the corpus (10 source rows, 11 authorities). A tool that fills the form from whatever website it was pointed at can actively induce this failure.",
  "phase": "approval",
  "automated": true,
  "attestation": {
    "question": "Is the legal entity on this brand the business whose name appears in the messages, rather than the agency or platform that sends them?",
    "howToCheck": [
      "Read one of your sample messages as a recipient would, and note which business it says is texting.",
      "Compare that business against the legal name and EIN on the brand. They must be the same entity.",
      "If you are an agency, ISV or reseller, your client is the brand and you are the CSP — register them, not yourself."
    ],
    "failureLooksLike": "The brand says Northstar Platform, Inc. and the message says \"Acme Coffee: your order is ready\". The consumer consented to hear from Acme, so Acme is the brand and Northstar is not."
  },
  "url": "https://ekas.io/rules/10dlc/brand/brd-160/",
  "markdown": "https://ekas.io/rules/10dlc/brand/brd-160.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}