Imported or legacy lists must evidence original consent
The requirementstatement
A campaign messaging a pre-existing list must describe when and how that consent was originally obtained.
- Severityseverity
- HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- campaign.message_flow
- 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
- CTIATCRFCC
- When it appliesapplicabilityText
- Applies when consent was collected by imported list.
Why this rule existsrationale
An existing customer relationship is not by itself consent to send marketing texts. Where the original opt-in cannot be described, there is nothing to audit, and the practical risk is that the list predates any SMS disclosure at all.
How to fix itremediation
Describe the original collection surface and approximate date, and attach evidence of the disclosure used then. Where you cannot, re-permission the list with a fresh opt-in before messaging it.
A compliant exampleexample
Numbers were collected between 2023 and 2026 at checkout on acmecoffee.com using the disclosure shown in the attached screenshot; the consent date is stored per record.
Rules you will hit next
6 other rules read campaign.message_flow. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.
CMP-003Message flow must not begin or end with whitespaceBlockingBLOCKINGCMP-059Message flow must describe the mechanism end to endBlockingBLOCKINGCMP-060Every opt-in method in use must be listed in the message flowBlockingBLOCKINGCMP-061Each declared method needs its own complete workflow paragraphBlockingBLOCKINGCMP-072Message flow must state the message typesBlockingBLOCKINGCMP-073Message flow must state message frequencyBlockingBLOCKING
CON-IMPORTED-LIST is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.