{
  "id": "CON-099",
  "slug": "con-099",
  "title": "The opt-in and its advertising must not mislead",
  "statement": "The consent disclosure and the programme advertising must not misrepresent what the programme is, what it costs, or what the consumer gets.",
  "rationale": "Deceptive opt-in copy produces subscribers who did not understand what they joined, and they behave exactly like people who never opted in: they complain, they report, and they tell the carrier the message was unsolicited. CTIA bans it at the call to action rather than only in the messages because the deception that matters most happens before consent, where it manufactures the consent itself.",
  "layer": "CONSENT_FLOW",
  "layerSlug": "consent-flow",
  "object": "consent disclosure text; programme advertising copy",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_WEBSITE",
  "authorities": [
    "CTIA",
    "T-Mobile",
    "AT&T"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Make the copy describe the programme accurately: what arrives, how often, what it costs, and what the consumer has to do. Remove anything implying a benefit the programme does not deliver or a cost it does not carry. Done when someone who reads only the CTA is not surprised by the first message.",
  "example": "Join Acme Coffee Rewards for offers and your rewards balance. Msg frequency varies. Msg & data rates may apply. No purchase necessary to join.",
  "pitfalls": [
    "Describing a paid programme as \"free\" is the specific case with its own rule and its own penalty — CON-101 — but any overstated benefit fails here."
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/consent-flow/con-099/",
  "markdown": "https://ekas.io/rules/10dlc/consent-flow/con-099.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}