# OPS-104 — Several states run their own do-not-call registry

> Where a state operates a registry that is not fully merged with the federal one, recipient lists must be scrubbed against it as well.

- **Rule ID:** OPS-104
- **Layer:** Operational (`OPERATIONAL`)
- **Checks:** `recipient list against state registries`
- **Severity:** HIGH — Rejected by at least one carrier or provider, and a common cause of failure at the rest.
- **When it bites:** Falls due after approval, once you are live and sending
- **How it is detected:** External record we cannot query — reported as a warning to verify
- **Fix type:** Wait on an external system or a required interval
- **Required by:** state law (TX, AZ and others)
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/operational/ops-104/

## Why this rule exists

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.

## How to fix it

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".

## Check this yourself

**Does your scrub step name every registry it consulted, rather than "the DNC list"?**

1. 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.
2. Add those scrubs to the same pre-send step as the federal one. Each is a separate subscription with its own access process.
3. Confirm state by state whether the registry covers texts at all. It is not uniform.

*What wrong looks like:* 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.

## 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.