A state may impose its own opt-out and identification duties

The requirementstatement

Where a state requires it, opt-out replies must be honoured and accurate sender identification maintained under that state's own rules.

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: opt-out handling and sender identification, per state
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: 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 (VA)
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

Virginia and states like it restate obligations the federal rules already impose, which sounds redundant and is not: the state version comes with its own enforcement route and its own penalties, so a failure is actionable twice. It matters most for sender identification, where the federal framing is a carrier expectation and the state framing is a statute.

How to fix itremediation

Identify the brand in every message and honour every opt-out immediately, which satisfies the state rules and the federal ones together. Done when no message leaves without the brand name in it.

Check this yourselfattestation

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

Does every message leaving your programme carry the brand name, and is every opt-out honoured immediately?

1Treat the strictest state as the standard rather than maintaining per-state behaviour: identification and immediate opt-out are cheap universally.
2Read a real delivered message and confirm the brand is identifiable in it.

What wrong looks like: Virginia and states like it restate federal duties with their own enforcement route and penalties, so one failure is actionable twice.

Notesnotes

State law applied to traffic we cannot see. What the user has to do is treat the strictest state as the standard rather than maintaining per-state behaviour — the identification and opt-out duties are cheap to satisfy universally and expensive to get wrong once.

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-113 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.