Several states run their own do-not-call registry

The requirementstatement

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

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: recipient list against state registries
Where it liveslayer: OperationalOPERATIONAL
How Ekas settles itdetectability: External recordEXTERNAL_DATA; The fact that settles it lives in a register we cannot query, such as the IRS file, a postal database, or another provider’s tenant. Reported as a warning with the evidence to check, not as a pass.
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: state law (TX, AZ and others)
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

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 itremediation

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 yourselfattestation

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

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

1List 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.
2Add those scrubs to the same pre-send step as the federal one. Each is a separate subscription with its own access process.
3Confirm 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.

Notesnotes

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.

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-104 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.