The opt-in and its advertising must not mislead
The requirementstatement
The consent disclosure and the programme advertising must not misrepresent what the programme is, what it costs, or what the consumer gets.
- 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
- consent disclosure text; programme advertising copy
- Where it liveslayer
- Consent flowCONSENT_FLOW
- 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
- Fix the websiteTERMINAL_WEBSITE
- The fix lives on your site. No amount of rewording the form clears it.
- Who requires itauthorities
- CTIAT-MobileAT&T
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
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.
How to fix itremediation
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.
A compliant exampleexample
Join Acme Coffee Rewards for offers and your rewards balance. Msg frequency varies. Msg & data rates may apply. No purchase necessary to join.
Common mistakespitfalls
- 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.
Rules you will hit next
Other consent flow rules at the same severity. A registration is judged as a whole, not rule by rule.
CON-008The live CTA and the declared message flow must say the same thingBlockingBLOCKINGCON-010The three subscriber-management attributes must be declared trueBlockingBLOCKINGCON-013Subscriber attributes must agree with the message bodies suppliedBlockingBLOCKINGCON-023Evidence URLs must resolve without a loginBlockingBLOCKINGCON-024The opt-in URL must serve a certificate that verifiesBlockingBLOCKINGCON-027The opt-in URL must land on a page that carries the opt-inBlockingBLOCKING
CON-099 is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.