{
  "id": "OPS-054",
  "slug": "ops-054",
  "title": "Revoking against an exempt message stops everything else too",
  "statement": "Where a consumer revokes in direct response to an exempted informational message, all further non-emergency robocalls and robotexts must stop.",
  "rationale": "Some informational messages need no prior consent, and operators reason from that to \"there is no consent here to revoke\". The FCC settled it the other way: replying stop to an exempt message is a revocation of everything non-emergency. The practical failure is a delivery-notification programme that keeps notifying after a stop, on the grounds that notifications were never opt-in.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "suppression scope after a revocation",
  "severity": "HIGH",
  "detectability": [
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Treat a revocation as brand-wide and category-blind unless the consumer narrowed it themselves. Done when a stop sent to a shipping notification also stops the marketing programme on the same number.",
  "notes": "Depends on which message a revocation answered, which only exists in the traffic. What the user has to check is whether their exempt or transactional flows consult the suppression list at all — many are built as system notifications that bypass it.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Do your transactional and exempt flows — shipping notices, alerts, system messages — consult the suppression list before sending?",
    "howToCheck": [
      "Trace one exempt flow end to end and find the suppression check. Many are built as system notifications that bypass it entirely.",
      "Test it: reply stop to a shipping notification and confirm the marketing programme on that number also stops."
    ],
    "failureLooksLike": "Operators reason that informational messages needed no consent, so there is none to revoke. The FCC settled it the other way, and a delivery-notification programme that keeps notifying after a stop is the practical failure."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-054/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-054.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}