{
  "id": "CMP-092",
  "slug": "cmp-092",
  "title": "Consent grade must match content grade",
  "statement": "The consent standard evidenced must match the content grade: conversational needs implied consent, informational needs express consent, promotional needs express written consent.",
  "rationale": "Consent comes in grades and content comes in grades, and the content grade sets the floor. A promotional programme resting on an implied consent collected for a service purpose is the most common structural consent failure — it looks like consent exists, and it is the wrong kind, so the brand cannot understand the rejection and re-submits the same evidence.",
  "layer": "CAMPAIGN",
  "layerSlug": "campaign",
  "object": "campaign.message_flow + campaign.usecase",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "CTIA",
    "FCC",
    "T-Mobile",
    "AT&T"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Raise the consent to match the content: promotional messaging needs express written consent — an affirmative, recorded agreement naming the sender and the message type. Re-collect it if what you hold was gathered for a service purpose; you cannot re-characterise consent after the fact. Done when the flow describes a written, affirmative act for every subscriber who will receive promotional content.",
  "example": "Promotional consent is collected in writing at checkout: the customer ticks an unchecked box beside the disclosure naming Acme Coffee and the message types, and we store the number, timestamp, and disclosure version.",
  "pitfalls": [
    "Splitting the campaign into a promotional one and a transactional one does not launder the consent — the promotional half still needs express written consent for each number on it."
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/campaign/cmp-092/",
  "markdown": "https://ekas.io/rules/10dlc/campaign/cmp-092.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}