{
  "id": "OPS-114",
  "slug": "ops-114",
  "title": "A programme relying on the delivery exemption still owes an opt-out",
  "statement": "A campaign relying on the package-delivery exemption must offer an opt-out and honour it within six business days.",
  "rationale": "The exemption removes the need for prior express consent, and brands read that as removing the consumer's ability to refuse — which is the one thing it does not do. The FCC attached conditions to every exemption it granted, and the opt-out is the condition that gets dropped, because a delivery notification feels like something nobody would want to stop.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "campaign.sample[] + campaign.message_flow",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Carry opt-out instructions in the exempt messages themselves and state the honouring window in the flow. Done when a delivery notification tells the recipient how to stop and the flow says how quickly that takes effect.",
  "example": "Acme Coffee: your order #4471 ships today, track at acmecoffee.com/t/4471. Reply STOP to stop delivery texts.",
  "notes": "Applies only where a campaign claims one of the FCC's exempted categories, which the registration has no attribute for. The condition sits in the criteria, and the note records that: a campaign that never invokes an exemption is not failed by this rule.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/operational/ops-114/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-114.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}