{
  "id": "OPS-323",
  "slug": "ops-323",
  "title": "An identity appeal has a window, and it runs from brand creation",
  "statement": "An identity-status appeal must be submitted within 45 calendar days of the brand being created, not of the decision being received.",
  "rationale": "The clock is the surprising part: it starts when the brand record is created, so a registration that sat in review for three weeks and was refused has already spent most of its appeal window before anybody saw the refusal. Teams plan the appeal around the rejection date, gather the CP-575, and file after the window shut — at which point the only route left is a new brand and a second set of fees.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "brand appeal submission vs brand creation date",
  "severity": "BLOCKING",
  "detectability": [
    "UNDETECTABLE_PRE_SUBMISSION"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "TCR"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Diarise the appeal deadline as 45 days from the day the brand was created, and gather the federal tax documentation while the review is still running rather than after a refusal. Done when the appeal is filed inside that window, with every page of the CP-575 or 147C attached.",
  "notes": "Not decidable here: no submitted field carries the brand creation date, so the registry cannot compute the deadline. Surfaced as a warning with the check the user has to run themselves — look up the brand's creation date in the registry console, add 45 days, and compare that to today before planning any appeal. BRD-260 and BRD-258 cover what the appeal must contain once you are inside the window.",
  "phase": "approval",
  "automated": false,
  "attestation": {
    "question": "What date was this brand created, and is today inside the 45 days that run from it?",
    "howToCheck": [
      "Look the brand's creation date up in the registry console — not the date of the refusal, which is what everyone plans around.",
      "Add 45 calendar days and compare that to today.",
      "Gather the federal tax documentation while the review is still running, so an appeal can be filed the day a refusal lands."
    ],
    "failureLooksLike": "A registration sat in review for three weeks and was refused, so most of the appeal window was spent before anyone saw the decision. Filing late leaves only a new brand and a second set of fees."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-323/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-323.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}