Debt collection cannot rest on a spoken opt-in
The requirementstatement
A debt-collection campaign must not collect its consent verbally.
- 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
- campaign.message_flow + brand.vertical
- Where it liveslayer
- CampaignCAMPAIGN
- How Ekas settles itdetectability
- AI · formAI_FORM
- A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
- What the fix involvesfailureClass
- Produce a documentTERMINAL_ARTIFACT
- Needs a document that does not exist yet, such as a verbal script, a paper consent form, or QR landing copy. Ekas drafts it.
- Who requires itauthorities
- Aerialink
- When it appliesapplicabilityText
- Applies when the vertical is debt_collection.
Why this rule existsrationale
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 itremediation
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 mistakespitfalls
- 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.
Notesnotes
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.
Rules you will hit next
Other campaign rules at the same severity. A registration is judged as a whole, not rule by rule.
CMP-003Message flow must not begin or end with whitespaceBlockingBLOCKINGCMP-017Every mandatory campaign attribute must be explicitly setBlockingBLOCKINGCMP-024Registration fields must be written in EnglishBlockingBLOCKINGCMP-028Opt-in evidence must be a JPG, PNG or PDF under 500 KBBlockingBLOCKINGCMP-035The description must describe this programme, not messaging in generalBlockingBLOCKINGCMP-037The description must name the business that sends the messagesBlockingBLOCKING
CMP-113 is one of 94 campaign rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.