{
  "id": "OPS-115",
  "slug": "ops-115",
  "title": "An exempt message must not cost the recipient anything",
  "statement": "Where an exemption requires it, exempted informational messages must not be charged to the called party or counted against their plan limits.",
  "rationale": "Several of the FCC exemptions are conditional on the message being free to the recipient, and a programme relying on the exemption while sending billable messages has not met the condition — so the exemption does not apply and the messages needed consent after all. It is a condition nobody controls from the sending side, which is exactly why it has to be checked rather than assumed.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "billing treatment of exempt messages",
  "severity": "MEDIUM",
  "detectability": [
    "HUMAN"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Confirm with the carrier or provider whether the traffic is free-to-end-user where the exemption requires it, and stop relying on that exemption where it is not. Done when the exemption you are relying on has had each of its conditions checked rather than only its category.",
  "notes": "Determined by the carrier and the recipient's plan, neither of which we see. What the user has to do is read the conditions attached to the specific exemption they are claiming — the category is the famous part and the conditions are where these fail.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "For the exemption you are relying on, has each of its conditions been checked — including whether the message is free to the recipient?",
    "howToCheck": [
      "Read the conditions attached to the specific exemption, not just its category. The category is the famous part and the conditions are where these fail.",
      "Confirm with the carrier or provider whether the traffic is free-to-end-user where the exemption requires it.",
      "Stop relying on that exemption where it is not."
    ],
    "failureLooksLike": "The programme sends billable messages under an exemption conditional on them being free. The condition is unmet, so the exemption does not apply and the messages needed consent after all."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-115/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-115.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}