Some states require the seller to register before texting residents

The requirementstatement

Before texting a state's residents, determine whether the seller must register with that state and post a bond.

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: state seller registration
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)
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

Texas requires telephone solicitors to register with the Secretary of State, per location, with a bond — an obligation that has nothing to do with the carriers and that no part of the 10DLC process mentions. It is discovered through an enforcement letter rather than a rejection, and the registration cannot be applied retrospectively to the sends already made.

How to fix itremediation

Check the seller-registration requirement for every state you solicit into before the first send, and register where it applies or exclude the state until you have. Done when the states you message are the states you are permitted to solicit in.

Check this yourselfattestation

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

For every state you solicit into, have you checked whether the seller must register and post a bond there?

1Take legal advice on which of your sends count as solicitations and which states they reach.
2Texas requires telephone solicitors to register with the Secretary of State, per location, with a bond.
3Register where it applies, or exclude the state until you have.

What wrong looks like: No part of the 10DLC process mentions it, so it arrives as an enforcement letter rather than a rejection — and the registration cannot be applied retrospectively to sends already made.

Notesnotes

A state filing, entirely outside the messaging stack. What the user has to do is take legal advice on which of their sends count as solicitations and which states they reach — carrier approval says nothing about either, and this is the clearest case in the framework where approval is not permission.

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-110 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.