The disclosure must be visible without the consumer opening anything
The requirementstatement
The consent disclosure must be rendered on the page as it loads — not behind a tooltip, an accordion, a "read more" toggle, or pushed out of the main content.
- 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
- disclosure rendering and DOM position
- Where it liveslayer
- Consent flowCONSENT_FLOW
- How Ekas settles itdetectability
- AI · crawlCRAWLAI · visionVISION
- Needs your live site or policy page fetched and read. Ekas crawls it the way a reviewer would. Needs the pixels: a screenshot of the opt-in surface, a scanned paper form, an MMS attachment.
- 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
- AttentiveTwilioInfobipFCC
- When it appliesapplicabilityText
- Applies when consent was NOT collected by live verbal and IVR.
Why this rule existsrationale
A disclosure the consumer has to reveal is one nearly all of them never see, and the law asks what a reasonable consumer would notice rather than what the page technically contains. Design teams collapse it in good faith, because a five-line legal block ruins a checkout — which is why the fix is usually about where the text sits rather than whether anyone wanted to hide it.
How to fix itremediation
Render the disclosure expanded by default in the main content, beside the control. Where the block is too long for the layout, shorten the wording rather than collapsing it — every required element fits in about forty words. Done when the text is readable on first paint with nothing clicked.
A compliant exampleexample
☐ Text me Acme Coffee offers. Msg frequency varies. Msg & data rates may apply. Reply STOP to unsubscribe, HELP for help. Terms · Privacy
Common mistakespitfalls
- An accordion that is open by default still fails on mobile, where the same component usually ships collapsed.
Notesnotes
Excluded from the verbal methods, which render nothing — a spoken script has no default state to reveal. Paper, POS and printed CTAs stay in scope: fine print on the reverse of a form is the same defect in another medium.
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-110 is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.