# OPS-323 — An identity appeal has a window, and it runs from brand creation

> An identity-status appeal must be submitted within 45 calendar days of the brand being created, not of the decision being received.

- **Rule ID:** OPS-323
- **Layer:** Operational (`OPERATIONAL`)
- **Checks:** `brand appeal submission vs brand creation date`
- **Severity:** BLOCKING — Breaking this rule gets the submission rejected outright.
- **When it bites:** Gates approval — get this wrong and registration is refused
- **How it is detected:** Not knowable before submission — reported with its deadline
- **Fix type:** Wait on an external system or a required interval
- **Required by:** TCR
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/operational/ops-323/

## Why this rule exists

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.

## How to fix it

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.

## Check this yourself

**What date was this brand created, and is today inside the 45 days that run from it?**

1. Look the brand's creation date up in the registry console — not the date of the refusal, which is what everyone plans around.
2. Add 45 calendar days and compare that to today.
3. Gather the federal tax documentation while the review is still running, so an appeal can be filed the day a refusal lands.

*What wrong looks like:* 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.

## 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.
