An exempt message must not cost the recipient anything

JSONMarkdown

The requirementstatement

Where an exemption requires it, exempted informational messages must not be charged to the called party or counted against their plan limits.

Severityseverity
MediumMEDIUMUsually survives review, but lowers your trust score or invites a manual look you would rather avoid.
When it bitesphase
After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
What is checkedobject
billing treatment of exempt messages
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
FCC
When it appliesapplicabilityText
Applies to every 10DLC registration.

Why this rule existsrationale

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.

How to fix itremediation

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.

Check this yourselfattestation

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

For the exemption you are relying on, has each of its conditions been checked — including whether the message is free to the recipient?

  1. 1Read the conditions attached to the specific exemption, not just its category. The category is the famous part and the conditions are where these fail.
  2. 2Confirm with the carrier or provider whether the traffic is free-to-end-user where the exemption requires it.
  3. 3Stop relying on that exemption where it is not.

What wrong looks like: 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.

Notesnotes

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.

Rules you will hit next

Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.

OPS-032A help request containing a stop-word is not an opt-outMediumMEDIUMOPS-042Somebody has to own revocations that arrive in conversationMediumMEDIUMOPS-050The opt-out confirmation is worth sending inside five minutesMediumMEDIUMOPS-051Only ask which messages to stop when there is more than one kindMediumMEDIUMOPS-057Log the sends you did not makeMediumMEDIUMOPS-062An opted-out consumer must be able to come backMediumMEDIUM

All operational rules

OPS-115 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.

Reading the rules is the easy part.

Ekas runs every rule that gates approval, 823 of these 915, against your registration before it reaches the carrier. It reads your site, your policy pages and your opt-in the way a reviewer would, and hands you the fix, not just the verdict.

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