{
  "id": "CMP-113",
  "slug": "cmp-113",
  "title": "Debt collection cannot rest on a spoken opt-in",
  "statement": "A debt-collection campaign must not collect its consent verbally.",
  "rationale": "Debt collection is already the most heavily litigated messaging category, and a spoken consent produces no record of what the debtor was told — so the one category where the consent record is most likely to be examined is the one where it would be weakest. The overlap with third-party collection matters too: that is refused outright at most providers, so a verbal opt-in here often signals a programme that has a larger problem than its consent method.",
  "layer": "CAMPAIGN",
  "layerSlug": "campaign",
  "object": "campaign.message_flow + brand.vertical",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_ARTIFACT",
  "artifact": "paper_consent_form",
  "authorities": [
    "Aerialink"
  ],
  "applicability": {
    "verticals": [
      "debt_collection"
    ]
  },
  "applicabilityText": "Applies when the vertical is debt_collection.",
  "universal": false,
  "remediation": "Collect written consent for the debt-collection programme — a signed form at account opening, or a portal opt-in the debtor completes themselves — and keep a copy of the disclosure version each debtor saw. Done when every number on the programme has a written record behind it.",
  "pitfalls": [
    "Consent obtained by the original creditor does not transfer to a third-party collector, so re-collecting is not optional even where a written record exists upstream."
  ],
  "notes": "Narrower than CMP-112, which refuses spoken consent for promotional content generally: this one refuses it for a whole vertical regardless of use case, because the exposure comes from the subject matter rather than from the content grade. Third-party debt collection is separately prohibited outright by the MSG-DEBT prohibition, which fires on content rather than on vertical.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/campaign/cmp-113/",
  "markdown": "https://ekas.io/rules/10dlc/campaign/cmp-113.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}