{
  "id": "BRD-200",
  "slug": "brd-200",
  "title": "A suspension follows the tax ID to the next brand",
  "statement": "After a suspension, new brands created on the same tax ID should be expected to be restricted.",
  "rationale": "The suspension attaches to the EIN rather than to the brand or the account, so it follows the business across providers — which means switching CSP does not reset it, and the new provider cannot lift it either. Businesses change provider precisely because the old one suspended them, and arrive at the same restriction with a second onboarding already paid for.",
  "layer": "BRAND",
  "layerSlug": "brand",
  "object": "brand.ein after a suspension",
  "severity": "BLOCKING",
  "detectability": [
    "EXTERNAL_DATA",
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "Twilio"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "21731",
      "remediable": false
    }
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Resolve the original suspension rather than moving. If the business genuinely has a new programme, expect the new brand to carry restrictions from the start and be ready to evidence what changed — the review will ask.",
  "notes": "Absorbs OPS-181, which states the same EIN-level scope across CSPs. Suspension history is not visible in a registration. What the user has to establish is whether this EIN has ever been suspended anywhere — the answer determines whether a new registration is worth attempting at all, and a provider change will not help.",
  "catalogIds": [
    "OPS-181"
  ],
  "phase": "approval",
  "automated": false,
  "attestation": {
    "question": "Has this tax ID ever been suspended, at any provider?",
    "howToCheck": [
      "Establish the suspension history for the EIN before starting a new registration. It attaches to the tax ID, not to the brand or the account, so changing provider does not reset it.",
      "Where a suspension exists, resolve it rather than moving — the new provider cannot lift it either.",
      "If the business genuinely has a new programme, be ready to evidence what changed. The review will ask."
    ],
    "failureLooksLike": "A business changes provider precisely because the old one suspended it, and arrives at the same restriction with a second onboarding already paid for."
  },
  "url": "https://ekas.io/rules/10dlc/brand/brd-200/",
  "markdown": "https://ekas.io/rules/10dlc/brand/brd-200.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}