{
  "id": "OPS-055",
  "slug": "ops-055",
  "title": "Revoke-all across categories has a deadline",
  "statement": "A suppression architecture that cannot revoke across every message category for a sender must be flagged before the federal revoke-all rule takes effect on 31 January 2027.",
  "rationale": "The rule is scheduled rather than hypothetical, and the work it implies is architectural: a brand whose consent and suppression are modelled per programme cannot become category-wide with a configuration change. Naming it now is what makes it a planned migration rather than a discovery made in the month it applies.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "suppression list data model",
  "severity": "LOW",
  "detectability": [
    "HUMAN"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Check now whether one revocation can suppress every category a sender operates, and if it cannot, schedule the change against the January 2027 date. Done when a single revocation demonstrably clears every programme the brand runs.",
  "effectiveFrom": "2027-01-31",
  "notes": "A future obligation about a system we cannot inspect, carried at LOW until it takes effect and BLOCKING after. What the user has to do is answer one question about their own platform — is suppression keyed per sender or per programme — and start the migration if the answer is the second.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Is suppression on your platform keyed per sender or per programme — and if per programme, is the migration scheduled against 31 January 2027?",
    "howToCheck": [
      "Answer the one architectural question: can a single revocation clear every category this sender operates?",
      "If it cannot, schedule the change now. A per-programme consent model does not become category-wide with a configuration change."
    ],
    "failureLooksLike": "The rule is scheduled rather than hypothetical, and it is discovered in the month it applies — when the work it implies is architectural rather than a setting."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-055/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-055.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}