{
  "id": "OPS-104",
  "slug": "ops-104",
  "title": "Several states run their own do-not-call registry",
  "statement": "Where a state operates a registry that is not fully merged with the federal one, recipient lists must be scrubbed against it as well.",
  "rationale": "A national programme that scrubs only the federal registry is unscrubbed in the states that kept their own, and two of those states are unusually expensive: Texas carries elevated penalties, and Arizona's coverage of text messages specifically is a question worth answering before sending rather than after. The gap is invisible because the federal scrub reports success either way.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "recipient list against state registries",
  "severity": "HIGH",
  "detectability": [
    "EXTERNAL_DATA"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "state law (TX, AZ and others)"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "List the states you message into, check which of them still run a separate registry, and add those scrubs to the same pre-send step as the federal one. Done when the scrub step names every registry it consulted rather than \"the DNC list\".",
  "notes": "Absorbs OPS-111 and OPS-112, which name Texas and Arizona specifically. Each state registry is a separate subscription with its own access process, and none of them is visible from here. What the user has to do is confirm coverage state by state — including whether the state registry covers texts at all, which is not uniform.",
  "catalogIds": [
    "OPS-111",
    "OPS-112"
  ],
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Does your scrub step name every registry it consulted, rather than \"the DNC list\"?",
    "howToCheck": [
      "List the states you message into and check which still run a separate registry — Texas carries elevated penalties and Arizona's coverage of texts specifically is worth settling before sending.",
      "Add those scrubs to the same pre-send step as the federal one. Each is a separate subscription with its own access process.",
      "Confirm state by state whether the registry covers texts at all. It is not uniform."
    ],
    "failureLooksLike": "A national programme that scrubs only the federal registry is unscrubbed in the states that kept their own — and the federal scrub reports success either way."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-104/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-104.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}