# CON-147 — An exemption relied on must be met in every one of its conditions

> Where a 47 CFR 64.1200(a)(9) exemption is relied on, every condition attached to it must be satisfied — free to the end user, within the message caps, sender identified, and opt-out in each message.

- **Rule ID:** CON-147
- **Layer:** Consent flow (`CONSENT_FLOW`)
- **Checks:** `exemption claim`
- **Severity:** BLOCKING — Breaking this rule gets the submission rejected outright.
- **When it bites:** Gates approval — get this wrong and registration is refused
- **How it is detected:** AI judgement over the submitted form
- **Fix type:** Supply evidence only you hold
- **Required by:** FCC
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/consent-flow/con-147/

## Why this rule exists

These exemptions are narrow and conditional, and failing any single condition collapses the whole thing back to needing consent — retrospectively, for everything already sent. The healthcare cap is the one most often missed: one message per day and three per week combined across voice and text, counted per patient rather than per programme.

## How to fix it

Go through the conditions for the specific exemption you are claiming and evidence each: that the messages are free to the recipient, that your declared frequency is inside the cap, that every message identifies you, and that every message carries an opt-out. Where any fails, collect consent instead and stop relying on the exemption.

## Example of a compliant value

```text
Package-delivery exemption: notifications are free to the recipient, one per shipment, identify Acme Coffee by name, and carry "Reply STOP to opt out" — honoured within six business days.
```

## Common mistakes

- The healthcare cap counts voice calls and texts together, so a practice already making reminder calls is usually over it before the SMS programme sends anything.

## Notes

The registry holds no free-to-end-user fact and no per-recipient frequency, so the conditions are pushed into the judgement criteria rather than expressed as applicability, and the rule only fires where the submission itself claims an exemption.