{
  "id": "OPS-038",
  "slug": "ops-038",
  "title": "Opt-out must not be reduced to one prescribed method",
  "statement": "Published opt-out instructions must not designate an exclusive revocation method — a consumer may use any reasonable channel.",
  "rationale": "The FCC rule is that a revocation counts however it reasonably arrives: a reply, a phone call, an email to an address the brand publishes. Copy saying \"the only way to unsubscribe is to reply STOP\" is not just narrower than the law, it is the sentence a plaintiff quotes — it shows the brand telling consumers their email revocation would not work, and it turns every revocation taken on another channel into an admission. Almost nobody writes it deliberately; it comes from terms boilerplate that names the mechanism the platform implements.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "campaign.message_flow + SMS terms + privacy policy",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "FCC",
    "CTIA",
    "T-Mobile",
    "AT&T"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Rewrite any \"only way\" wording so STOP is offered as the easiest route rather than the sole one, and name at least one non-SMS channel — the support email or phone number you already publish. Done when no sentence in the flow, the terms or the policy tells a consumer that a revocation sent another way will not be honoured.",
  "example": "Reply STOP to any message to unsubscribe. You can also opt out by emailing support@acmecoffee.com or calling 415-555-0134, and we honour requests received any of these ways.",
  "pitfalls": [
    "Adding the extra channels to the terms while the HELP reply still says STOP is the only method leaves the exclusive sentence in the one place a consumer actually reads."
  ],
  "notes": "Registration-side twin. Whether a revocation sent by email is honoured is runtime conduct we cannot observe; whether the brand has told consumers it will not be is in the submitted text, and it is the half a reviewer reads too.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/operational/ops-038/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-038.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}