A registry snapshot older than a month is not a scrub

The requirementstatement

The national registry version used for a scrub must be no more than 31 days old at the time the message is sent.

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: registry snapshot age at send time
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

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.

How to fix itremediation

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 Done when an out-of-date snapshot blocks a send instead of producing a log line.

A compliant exampleexample

Scrub record: registry_version 2026-03-01, scrubbed_at 2026-03-04, send_at 2026-03-04 — 3 days old, allowed.

Check this yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

Does an out-of-date registry snapshot block a send, or only produce a log line?

1Record the registry version date on every scrub and refuse the send when it is over 31 days old.
2Check the refresh is scheduled and monitored — an unmonitored download that started failing silently is the usual cause.

What wrong looks like: 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.

Notesnotes

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.

Rules you will hit next

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

OPS-034A programme in another language still owes the English keywordHighHIGH OPS-035The mandatory keywords must work over MMS tooHighHIGH OPS-044Suppression is brand-wide, not per numberHighHIGH OPS-047A state may give you less time than the federal limitHighHIGH OPS-052Silence after a scope question revokes everythingHighHIGH OPS-053A STOP answering a scope question must not be answered with anotherHighHIGH

All operational rules

OPS-103 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.