Revoking against an exempt message stops everything else too
The requirementstatement
Where a consumer revokes in direct response to an exempted informational message, all further non-emergency robocalls and robotexts must stop.
- Severityseverity
- HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
- When it bitesphase
- After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
- What is checkedobject
- suppression scope after a revocation
- 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
- FCC
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
How to fix itremediation
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.
Check this yourselfattestation
No tool can settle this one for you. Here is the check, and what wrong looks like.
Do your transactional and exempt flows — shipping notices, alerts, system messages — consult the suppression list before sending?
- 1Trace one exempt flow end to end and find the suppression check. Many are built as system notifications that bypass it entirely.
- 2Test it: reply stop to a shipping notification and confirm the marketing programme on that number also stops.
What wrong looks like: 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.
Notesnotes
Rules you will hit next
Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.
OPS-054 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.