{
  "id": "OPS-103",
  "slug": "ops-103",
  "title": "A registry snapshot older than a month is not a scrub",
  "statement": "The national registry version used for a scrub must be no more than 31 days old at the time the message is sent.",
  "rationale": "The registry changes daily, so a stale snapshot removes the people who registered before your download and none of the people who registered after it — and the freshness requirement exists precisely because a scrub against a year-old file looks identical in the logs to a scrub against yesterday's. The failure mode is a pipeline that downloads once and caches indefinitely because nothing ever errors.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "registry snapshot age at send time",
  "severity": "HIGH",
  "detectability": [
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Record the registry version date on every scrub and refuse the send when it is over 31 days old rather than warning about it. Done when an out-of-date snapshot blocks a send instead of producing a log line.",
  "example": "Scrub record: registry_version 2026-03-01, scrubbed_at 2026-03-04, send_at 2026-03-04 — 3 days old, allowed.",
  "notes": "A property of a pipeline we cannot see. What the user has to check is whether the refresh is scheduled and monitored — an unmonitored download that started failing silently is the usual cause, and the scrub keeps reporting success throughout.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Does an out-of-date registry snapshot block a send, or only produce a log line?",
    "howToCheck": [
      "Record the registry version date on every scrub and refuse the send when it is over 31 days old.",
      "Check the refresh is scheduled and monitored — an unmonitored download that started failing silently is the usual cause."
    ],
    "failureLooksLike": "The pipeline downloads once and caches indefinitely because nothing ever errors. A scrub against a year-old file looks identical in the logs to a scrub against yesterday's, and the scrub keeps reporting success throughout."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-103/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-103.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}