A suspension follows the tax ID to the next brand

The requirementstatement

After a suspension, new brands created on the same tax ID should be expected to be restricted.

Severityseverity: BlockingBLOCKINGBreaking this rule gets the submission rejected. There is no partial credit.
When it bitesphase: Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
What is checkedobject: brand.ein after a suspension
Where it liveslayer: BrandBRAND
How Ekas settles itdetectability: External recordEXTERNAL_DATAPost-submissionUNDETECTABLE_PRE_SUBMISSION; The fact that settles it lives in a register we cannot query, such as the IRS file, a postal database, or another provider’s tenant. Reported as a warning with the evidence to check, not as a pass. The subject does not exist yet at submission time: a reply window, an expiring PIN, a queue position. Reported with its deadline.
What the fix involvesfailureClass: Wait on someone elseTERMINAL_EXTERNAL; Needs an external system or a waiting period, such as IRS propagation, a vetting result, or a carrier queue.
Who requires itauthorities: Twilio
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

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.

How to fix itremediation

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.

Provider rejection codescodes

The code you get back when this rule is what failed, and whether that provider lets you resubmit.

Provider	Code	Resubmit
Twilio	21731	No

Check this yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

Has this tax ID ever been suspended, at any provider?

1Establish 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.
2Where a suspension exists, resolve it rather than moving — the new provider cannot lift it either.
3If the business genuinely has a new programme, be ready to evidence what changed. The review will ask.

What wrong looks like: A business changes provider precisely because the old one suspended it, and arrives at the same restriction with a second onboarding already paid for.

Notesnotes

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.

Rules you will hit next

Other brand rules at the same severity. A registration is judged as a whole, not rule by rule.

BRD-001A legal company name is required for every entity but a sole proprietorBlockingBLOCKING BRD-002Legal name must match the IRS record for the EINBlockingBLOCKING BRD-003Legal name must carry its exact entity suffix as filedBlockingBLOCKING BRD-008Legal name must not carry an appended personal name or roleBlockingBLOCKING BRD-009The legal name field takes the legal name, not the trading nameBlockingBLOCKING BRD-011A legal business name may back only one brand across the whole registryBlockingBLOCKING

All brand rules

BRD-200 is one of 196 brand rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.