{
  "id": "MSG-209",
  "slug": "msg-209",
  "title": "A charity programme may not run games of chance or recurring donations",
  "statement": "A campaign registered under the CHARITY use case must not solicit lottery, sweepstakes or raffle entries, and must not enrol donors in recurring donations.",
  "rationale": "The charity use case buys favourable treatment — higher throughput, a lighter consent standard than marketing — on the basis that the traffic is mission communication to supporters. Games of chance and recurring billing are the two things that turn it into a payment funnel, and both carry the harms the concession was never meant to cover: a raffle is gambling however good the cause, and a recurring donation enrolled by text is a subscription the donor cannot see, cancel or reconcile. Charities are caught out by this constantly and in complete good faith, because the raffle at the fundraising dinner and the monthly giving programme are the two most normal things a small charity does.",
  "layer": "MESSAGE_CONTENT",
  "layerSlug": "message-content",
  "object": "campaign.sample[] + campaign.description",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "T-Mobile",
    "CTIA"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "30462",
      "remediable": false
    }
  ],
  "applicability": {
    "useCases": [
      "CHARITY"
    ]
  },
  "applicabilityText": "Applies when the use case is CHARITY.",
  "universal": false,
  "remediation": "Take the draw and the recurring enrolment out of the text programme and keep both on the web, where the donor sees the terms and the billing schedule. The messages may link to them; they may not run them. Done when no sample asks for an entry, a ticket or a monthly commitment, and every donation ask in the campaign is for a single gift.",
  "example": "Riverside Shelter: our winter beds are at capacity tonight and we need blankets. Give once at https://riversideshelter.org/give Reply STOP to opt out, HELP for help.",
  "pitfalls": [
    "Linking to the raffle page rather than selling tickets in the thread is the fix; describing the raffle in the message and linking to it is still soliciting entries and still fails."
  ],
  "notes": "CTIA dropped this from the Short Code Monitoring Handbook at v1.9 while T-Mobile section 6.7 retains it, so it is a live requirement on the strictest reading rather than a historical one. Divergence recorded; strictest reading kept.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/message-content/msg-209/",
  "markdown": "https://ekas.io/rules/10dlc/message-content/msg-209.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}