{
  "id": "CON-078",
  "slug": "con-078",
  "title": "Printed and in-store consent must not gate the transaction",
  "statement": "Paper forms, till screens and printed advertising must not make SMS consent a condition of the purchase, the discount, or completing the form.",
  "rationale": "The counter is where consent is most easily coerced and least easily evidenced: a customer being asked in front of a queue for their number to \"finish the transaction\" says yes to get out of the shop. Nothing about that is legible afterwards, which is exactly why carriers judge the printed artwork and the terminal screen rather than the brand's account of what staff say.",
  "layer": "CONSENT_FLOW",
  "layerSlug": "consent-flow",
  "object": "paper form copy; POS screen; print CTA artwork",
  "severity": "BLOCKING",
  "detectability": [
    "VISION"
  ],
  "failureClass": "TERMINAL_ARTIFACT",
  "artifact": "paper_consent_form",
  "authorities": [
    "FCC",
    "T-Mobile",
    "Klaviyo"
  ],
  "applicability": {
    "consentMethods": [
      "paper",
      "pos",
      "employer_hr"
    ]
  },
  "applicabilityText": "Applies when consent was collected by paper form, point of sale and employer / HR.",
  "universal": false,
  "remediation": "Reprint the form or artwork so the messaging tick box sits apart from anything required, carrying \"Consent is not a condition of any purchase.\" Change the till prompt so staff can complete the sale without the number, and brief them that \"skip\" is a normal answer. Done when a customer who declines gets the same price and the same receipt.",
  "pitfalls": [
    "Artwork reading \"Text JOIN to 55512 for 20% off\" makes the discount conditional on the opt-in even where the paper form beside it is clean — the print is the CTA a reviewer judges.",
    "A required phone line on an intake or warranty form gates it just as effectively as a tick box does, because staff will not hand back an incomplete form."
  ],
  "catalogIds": [
    "CON-077",
    "CON-079"
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/consent-flow/con-078/",
  "markdown": "https://ekas.io/rules/10dlc/consent-flow/con-078.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}