{
  "id": "POL-189",
  "slug": "pol-189",
  "title": "The terms must distinguish transactional from promotional messages",
  "statement": "Where the programme sends both transactional and promotional messages, the terms must distinguish them and describe the separate consent.",
  "rationale": "The two categories carry different consent standards, and a subscriber who agreed to order updates has not agreed to weekly offers — bundling them is the defect Twilio codes at the campaign level. A document that lumps them together makes the bundling official, which is worse for the brand than the practice alone.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "SMS terms body",
  "severity": "HIGH",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "sms_terms",
  "authorities": [
    "Twilio"
  ],
  "codes": [
    {
      "provider": "Twilio",
      "code": "30913",
      "remediable": true,
      "generation": "gen1"
    }
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Describe the two categories separately in the terms and say that promotional messages need their own opt-in. Done when a reader can tell which consent covers which messages.",
  "example": "Order updates are sent to every customer who places an order. Promotional offers are sent only to customers who ticked the marketing box — you can receive one without the other.",
  "notes": "Applies only where both categories are sent; the criteria pass immediately for a single-category programme, since there is nothing to distinguish.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-189/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-189.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}