A spoken opt-in needs a per-consumer artifact, not just a script
The requirementstatement
Verbal consent must be evidenced per consumer by a recording, a transcript, or documented contemporaneous notes — never by the script alone.
- 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
- 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
- FTCpractice
- When it appliesapplicabilityText
- Applies when consent was collected by live verbal and IVR.
Why this rule existsrationale
The script proves what the programme intends to say. It is silent about any particular call, so a brand holding only a script has one document and no evidence, and finds that out when a single complaint asks about a single consumer. The transcript or the note is the substitute a reviewer accepts when a recording does not exist, which is why the rule names three acceptable forms rather than demanding audio.
How to fix itremediation
Name in the message flow which artifact is kept per consumer — recording, transcript, or a contemporaneous CRM note carrying the verbatim assent — and keep it against the number. Done when the flow says what exists for one named consumer, not what the agents are told to say.
A compliant exampleexample
Each phone opt-in retains the call recording; where the consumer declines recording, the agent stores the verbatim assent and the script version in the CRM against the number.
Notesnotes
Absorbs OPS-234, which states the transcript fallback inside the same record requirement. Whether a recording can stand as WRITTEN consent for a marketing programme is a different question and is judged by CON-156; this rule asks only whether any per-consumer artifact exists.
Rules you will hit next
6 other rules read campaign.message_flow. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.
CMP-003Message flow must not begin or end with whitespaceBlockingBLOCKINGCMP-059Message flow must describe the mechanism end to endBlockingBLOCKINGCMP-060Every opt-in method in use must be listed in the message flowBlockingBLOCKINGCMP-061Each declared method needs its own complete workflow paragraphBlockingBLOCKINGCMP-072Message flow must state the message typesBlockingBLOCKINGCMP-073Message flow must state message frequencyBlockingBLOCKING
OPS-232 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.