{
  "id": "CON-076",
  "slug": "con-076",
  "title": "Opt-in must not be bought with a prize or giveaway entry",
  "statement": "A messaging opt-in must not be offered in exchange for entry to a prize draw, giveaway, raffle or contest.",
  "rationale": "An opt-in given to enter a draw says nothing about wanting the messages, so the list that results behaves like a purchased one: high opt-out rates, high complaint rates, and recipients who do not recognise the sender by the second send. The research names this the highest-frequency trap for legitimate brands, because \"enter to win — text WIN to join\" is a normal-looking retail promotion that nobody involved thinks of as a compliance decision.",
  "layer": "CONSENT_FLOW",
  "layerSlug": "consent-flow",
  "object": "opt-in offer copy",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_WEBSITE",
  "authorities": [
    "Twilio",
    "CTIA",
    "T-Mobile"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "30945",
      "remediable": false,
      "generation": "gen2"
    }
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Separate the two decisions: let people enter the draw without joining the list, and offer the messaging opt-in beside it as its own optional control with its own disclosure. Done when the entry form completes with the SMS box unticked and the prize is never described as what the opt-in earns.",
  "example": "☐ Enter me in the monthly Acme Coffee hamper draw.\n☐ Separately, text me Acme Coffee offers. Consent is not a condition of entry. Msg frequency varies. Msg & data rates may apply. Reply STOP to unsubscribe.",
  "pitfalls": [
    "Making the draw entry the reward for opting in and the opt-in optional \"in theory\" still fails — the question is what the copy offers, not what the checkbox allows.",
    "A genuine sweepstakes can be registered, under the sweepstakes use case with official rules; what cannot be done is paying for opt-ins with entries."
  ],
  "notes": "Twilio 30945 is non-remediable at that provider — the campaign cannot be resubmitted once rejected for it — which is why catching it before submission matters more here than for most rules. Whether contest content in the samples needs the sweepstakes use case is MSG-155, not this rule.",
  "catalogIds": [
    "MSG-208"
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/consent-flow/con-076/",
  "markdown": "https://ekas.io/rules/10dlc/consent-flow/con-076.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}
