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

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.

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?

  1. 1Trace one exempt flow end to end and find the suppression check. Many are built as system notifications that bypass it entirely.
  2. 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

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.

Rules you will hit next

Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.

All operational rules

OPS-054 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.