{
  "id": "POL-233",
  "slug": "pol-233",
  "title": "The document dates must not predate the last change to the programme",
  "statement": "The last-updated dates on the privacy policy and the terms must be no older than the last material change to the messaging programme.",
  "rationale": "A programme that gained a message category last month, documented by terms dated two years ago, is telling subscribers about a programme that no longer exists — and CTIA asks for up-to-date information rather than merely dated information. The dates are the cheapest way for a reviewer to spot it, which makes a stale date an invitation to read the rest more carefully.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy + terms dates vs the last programme change",
  "severity": "MEDIUM",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "sms_terms",
  "authorities": [
    "CTIA"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Update both documents whenever the programme changes materially — a new message category, a new opt-in surface, a changed frequency — and set the date by hand when you do. Done when both dates are at least as recent as the last change.",
  "example": "Programme gained cart reminders in June 2026; both documents now read \"Last updated: 1 July 2026\".",
  "notes": "Authored as a judgement rather than as a predicate on purpose. Comparing a published date against a change that happened \"N days ago\" needs a clock, and a rule whose verdict changes with the calendar cannot be pinned by a fixture — the corpus would drift silently. The judge is given the campaign fields, which carry how long ago the programme last changed where the caller knows it. Whether a date is present at all is POL-141.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-233/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-233.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}