The consent record must capture the number it authorises
The requirementstatement
The consent record must store the specific telephone number the consumer authorised messages to be sent to.
- 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 artifact phone field
- Where it liveslayer
- Consent flowCONSENT_FLOW
- How Ekas settles itdetectability
- AI · crawlCRAWL
- Needs your live site or policy page fetched and read. Ekas crawls it the way a reviewer would.
- What the fix involvesfailureClass
- Supply evidenceTERMINAL_EVIDENCE
- Needs proof only you hold: a screenshot, a recording, a scan of the form people signed.
- Who requires itauthorities
- FCCSIP.US
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
The federal definition of written consent turns on the number the signatory authorised, so a record proving somebody consented without recording which number they consented for cannot be matched to the message that was sent. It is the failure that surfaces late and badly: the brand has thousands of consent records and cannot tie any of them to the number in the complaint.
How to fix itremediation
Store the number on the consent record itself, in the form it was given, next to the timestamp and the disclosure version. Done when you can take any number from your sending list and produce the record that authorised it.
A compliant exampleexample
Each consent record stores: phone number, timestamp, collection surface, disclosure version shown, and the session or agent identity.
Common mistakespitfalls
- Storing consent against a customer account rather than a number breaks the moment somebody changes their number, and the old number stays on the sending list with a record that no longer describes it.
Notesnotes
Judged from what the flow and the artifact say about the record, since the record itself is the brand's own system. OPS-205 states the same field requirement on the retained record.
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-137 is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.