# CMP-113 — Debt collection cannot rest on a spoken opt-in

> A debt-collection campaign must not collect its consent verbally.

- **Rule ID:** CMP-113
- **Layer:** Campaign (`CAMPAIGN`)
- **Checks:** `campaign.message_flow + brand.vertical`
- **Severity:** BLOCKING — Breaking this rule gets the submission rejected outright.
- **When it bites:** Gates approval — get this wrong and registration is refused
- **How it is detected:** AI judgement over the submitted form
- **Fix type:** Produce a document that does not exist yet
- **Required by:** Aerialink
- **Applies:** Applies when the vertical is debt_collection.
- **Canonical URL:** https://ekas.io/rules/10dlc/campaign/cmp-113/

## Why this rule exists

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.

## How to fix it

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.

## Common mistakes

- 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.