Consent records must capture all seven required fields
The requirementstatement
The programme must retain a consent record holding the number, timestamp, medium, a capture of the consent experience, the campaign, an IP or call identifier, and the consenting party.
- Severityseverity
- HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- campaign.message_flow + privacy policy
- Where it liveslayer
- OperationalOPERATIONAL
- How Ekas settles itdetectability
- AI · formAI_FORM
- A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
- What the fix involvesfailureClass
- Fix the fieldRETRY_FIELD
- A better value in the form fixes it. Ekas can rewrite it and re-check.
- Who requires itauthorities
- CTIAFCCTCR
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
How to fix itremediation
Store all seven fields per opt-in, and version the disclosure text so you can reproduce exactly what a given consumer saw. Describe this in the message flow — a reviewer treats an undescribed record-keeping practice as an absent one.
A compliant exampleexample
For each opt-in we store: phone number, UTC timestamp, acquisition medium, the versioned disclosure text shown, the campaign, the originating IP (or call ID for phone consent), and the account or session identity that consented.
Common mistakespitfalls
- Storing a boolean flag with a date is the most common shortfall — it cannot answer "what did they agree to?".
Rules you will hit next
6 other rules read campaign.message_flow + privacy policy. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.
OPS-199 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.