An exemption relied on must be met in every one of its conditions

The requirementstatement

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.

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: exemption claim
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: Supply evidenceTERMINAL_EVIDENCE; Needs proof only you hold: a screenshot, a recording, a scan of the form people signed.
Who requires itauthorities: FCC
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

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 itremediation

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.

A compliant exampleexample

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 mistakespitfalls

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.

Notesnotes

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.

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 thingBlockingBLOCKING CON-010The three subscriber-management attributes must be declared trueBlockingBLOCKING CON-013Subscriber attributes must agree with the message bodies suppliedBlockingBLOCKING CON-023Evidence URLs must resolve without a loginBlockingBLOCKING CON-024The opt-in URL must serve a certificate that verifiesBlockingBLOCKING CON-027The opt-in URL must land on a page that carries the opt-inBlockingBLOCKING

All consent flow rules

CON-147 is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.