The internal do-not-call list is checked on every send

The requirementstatement

Every send must be scrubbed against the brand's own company-specific do-not-call list.

Severityseverity: BlockingBLOCKINGBreaking this rule gets the submission rejected. There is no partial credit.
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 the internal do-not-call list
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 internal list holds the people who told this brand directly to stop, which makes messaging them the most obviously indefensible version of the failure — and unlike the federal registry there is no exemption, no relationship carve-out and no argument available. It gets skipped because the internal list often lives in the CRM rather than in the sending platform, so the send pipeline never consults it.

How to fix itremediation

Put the internal list where the send pipeline can read it, and check it at send time on every campaign — not only on solicitations. Done when a number on the internal list cannot be reached by any campaign the brand runs.

Check this yourselfattestation

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

Are the internal do-not-call list and the SMS suppression list the same list, or synchronised both ways?

1Find where the internal list lives. It is usually the CRM, which is why the send pipeline never consults it.
2Put it where the pipeline can read it and check it at send time on every campaign, not only on solicitations.
3Where the two lists are separate, establish which one is stale — one of them always is.

What wrong looks like: These are the people who told this brand directly to stop. There is no exemption, no relationship carve-out and no argument available.

Notesnotes

A list inside the brand, consulted by a pipeline we cannot see. What the user has to verify is that the internal list and the SMS suppression list are the same list, or are synchronised both ways — where they are separate, one of them is always stale. OPS-044 covers the brand-wide scope this depends on.

Rules you will hit next

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

OPS-026The universal opt-out keyword set must be declaredBlockingBLOCKING OPS-027Opt-out keyword handling must be declared, not assumedBlockingBLOCKING OPS-029A revocation must survive punctuation, case and surrounding wordsBlockingBLOCKING OPS-031A plainly-worded opt-out counts even with no keyword in itBlockingBLOCKING OPS-033STOP must never come back as an errorBlockingBLOCKING OPS-037On a shared address, STOP must stop everythingBlockingBLOCKING

All operational rules

OPS-105 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.