A business built on acquiring opt-in lists cannot be registered
The requirementstatement
A campaign whose business model is acquiring, aggregating or monetising opt-in subscriber lists must not be registered.
- 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
- campaign business model
- 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
- Hard stopHARD_STOP
- Not remediable. Resubmitting will not help, and anyone offering to fix it is selling you a rejection.
- Who requires itauthorities
- AT&TBandwidthTwilioCTIA
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
Where the list IS the product, no amount of documentation fixes the campaign, because the consumers on it agreed to hear from whoever collected them and not from whoever bought them. Carriers name lead generation specifically in their prohibited categories for this reason, and the enforcement history behind 10DLC is largely this business model.
How to fix itremediation
A lead-generation or list-acquisition programme cannot be registered under any use case. The only messaging that can be is to consumers who opted in to hear from this brand directly, under this brand's own name.
Notesnotes
Distinct from CON-NO-TRANSFER, which asks where one list came from. This asks what the business does: a retailer that once bought a list has a fixable provenance problem, while a lead vendor has nothing to fix.
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-139 is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.