{
  "id": "OPS-385",
  "slug": "ops-385",
  "title": "A referral programme must not pay people to forward messages",
  "statement": "Consumers who send viral or referral messages must receive nothing of value for doing so.",
  "rationale": "Paying for forwards turns the sender's friends into a purchased audience: the recipient gets a message from someone they trust, sent for a reward rather than because it was relevant, and there is no consent anywhere in the chain. It is the one part of referral marketing the industry prohibits outright, and it is easy to walk into — a discount for a successful invite is exactly the mechanic every growth playbook recommends.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "campaign.description + campaign.message_flow + campaign.sample[]",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "RETRY_FIELD",
  "authorities": [
    "CTIA"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Remove the incentive from the forwarding step. Reward the new subscriber's own opt-in if you want a referral mechanic at all, and have the invitee opt in on your own surface rather than receiving a message the referrer triggered. Done when nothing of value depends on a consumer sending a message to somebody else.",
  "example": "Share Acme Coffee with a friend — when they sign up at acmecoffee.com/join they get 20% off their first order. (The reward goes to the new customer, not to the referrer.)",
  "pitfalls": [
    "Sweepstake entries, loyalty points and account credit all count as something of value; the prohibition is not limited to cash."
  ],
  "notes": "Applies only to viral and referral programmes, which the registration has no attribute for. The judge is told to PASS immediately where the campaign describes no forwarding mechanic, and this note records the carve-out the applicability model cannot express.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/operational/ops-385/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-385.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}