Opt-out must not be reduced to one prescribed method
The requirementstatement
Published opt-out instructions must not designate an exclusive revocation method — a consumer may use any reasonable channel.
- 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
- campaign.message_flow + SMS terms + privacy policy
- Where it liveslayer
- OperationalOPERATIONAL
- 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
- Fix the fieldRETRY_FIELD
- A better value in the form fixes it. Ekas can rewrite it and re-check.
- Who requires itauthorities
- FCCCTIAT-MobileAT&T
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
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.
How to fix itremediation
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.
A compliant exampleexample
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.
Common mistakespitfalls
- 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.
Notesnotes
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.
Rules you will hit next
Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.
OPS-026The universal opt-out keyword set must be declaredBlockingBLOCKINGOPS-027Opt-out keyword handling must be declared, not assumedBlockingBLOCKINGOPS-029A revocation must survive punctuation, case and surrounding wordsBlockingBLOCKINGOPS-031A plainly-worded opt-out counts even with no keyword in itBlockingBLOCKINGOPS-033STOP must never come back as an errorBlockingBLOCKINGOPS-037On a shared address, STOP must stop everythingBlockingBLOCKING
OPS-038 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.