The scrub process needs writing down, version dates included

The requirementstatement

The registry access and scrub process must be documented, including the registry version date used for each scrub.

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: scrub process documentation
Where it liveslayer: OperationalOPERATIONAL
How Ekas settles itdetectability: Human checkHUMAN; Only someone holding the document or making the call can settle it. Ekas tells you exactly what to look at.
What the fix involvesfailureClass: Supply evidenceTERMINAL_EVIDENCE; Needs proof only you hold: a screenshot, a recording, a scan of the form people signed.
Who requires itauthorities: FCC
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

The defence to a registry claim is the scrub, and a scrub with no record of which registry version it used cannot answer the only question that matters — whether the number was on the list at the time. Documenting the process is also what makes the freshness requirement auditable rather than aspirational.

How to fix itremediation

Write down who holds the registry subscription, how often it is refreshed, where the scrub runs in the send pipeline, and store the version date with every scrub result. Done when any past send can be tied to the registry version that cleared it.

A compliant exampleexample

Scrub log: send acme-2026-03-04, registry_version 2026-03-01, 40,000 in, 312 removed.

Check this yourselfattestation

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

Can any past send be tied to the registry version that cleared it?

1Write down who holds the registry subscription, how often it is refreshed, and where the scrub runs in the send pipeline.
2Store the version date with every scrub result — most scrub tooling logs a result and a count and drops the version.

What wrong looks like: A scrub with no record of which registry version it used cannot answer the only question that matters: whether the number was on the list at the time.

Notesnotes

Documentation and logs inside the brand. What the user has to do is keep the version date specifically — most scrub tooling logs a result and a count and drops the version, which leaves the record unable to answer the question it exists for.

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-109 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.