A revocation on any channel must reach the SMS suppression list

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The requirementstatement

Revocations captured by an IVR key-press, a live agent, a designated website or number, an email or a voicemail must all be written into the same suppression list as a texted STOP.

Severityseverity
BlockingBLOCKINGBreaking this rule gets the submission rejected. There is no partial credit.
When it bitesphase
After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
What is checkedobject
suppression list ingestion across channels
Where it liveslayer
OperationalOPERATIONAL
How Ekas settles itdetectability
Post-submissionUNDETECTABLE_PRE_SUBMISSION
The subject does not exist yet at submission time: a reply window, an expiring PIN, a queue position. Reported with its deadline.
What the fix involvesfailureClass
Wait on someone elseTERMINAL_EXTERNAL
Needs an external system or a waiting period, such as IRS propagation, a vetting result, or a carrier queue.
Who requires itauthorities
FCCCTIA
When it appliesapplicabilityText
Applies to every 10DLC registration.

Why this rule existsrationale

The consumer does not know your systems are separate. They tell the agent on the phone, or reply to the marketing email, and consider it done — and the FCC agrees with them: a revocation received at any address or number the brand holds out is presumed effective. What actually happens is that the CRM records a preference nobody syncs, the shared inbox is read by a team with no access to the messaging platform, and the texts continue for weeks.

How to fix itremediation

Give every intake channel one write path into the suppression list — an API call, a shared field the messaging platform reads, or a queue somebody works daily — and record the channel on each record. Done when a revocation left on voicemail suppresses the number without anyone re-keying it.

A compliant exampleexample

Agent marks "SMS opt-out" in the CRM → nightly job (or webhook) writes the number to the messaging platform suppression list with channel=phone.

Common mistakespitfalls

  • A one-way sync from the messaging platform into the CRM is the common build and it is backwards — the revocations that need moving are the ones that arrive outside the messaging platform.

Check this yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

Can you name every place a customer could say stop — agents, shop staff, the support inbox, social messages, voicemail — and show that each one reaches the suppression list?

  1. 1List the intake channels, then trace one revocation through each to the list.
  2. 2Check the direction of any existing CRM sync: the common build is one-way out of the messaging platform, which is backwards.
  3. 3Test the hardest one — leave a revocation on voicemail and see whether the number is suppressed without anyone re-keying it.

What wrong looks like: The CRM records a preference nobody syncs, the shared inbox is read by a team with no access to the messaging platform, and the texts continue for weeks. The consumer considered it done, and so does the FCC.

Notesnotes

Absorbs OPS-040 and OPS-041, which name the designated-channel and email or voicemail cases of the same routing duty. Nothing here is visible at registration. The user has to list every place a customer could plausibly say stop — agents, shop staff, the support inbox, social messages — and show that each one reaches the list. OPS-038 is the registration-side twin: the published instructions must not name one exclusive method.

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

All operational rules

OPS-039 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.

Reading the rules is the easy part.

Ekas runs every rule that gates approval, 823 of these 915, against your registration before it reaches the carrier. It reads your site, your policy pages and your opt-in the way a reviewer would, and hands you the fix, not just the verdict.

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