Verbal Script Text Missing
Why This Rejection Happens
You indicated that users opt-in via a verbal or phone-based method, but you did not provide the actual script that your agents read to consumers. Vetting agents cannot approve a consent flow they cannot read.
Common Triggers: Selecting "Verbal" as the opt-in method but leaving the script field blank, or uploading a file without pasting the text into the description.
Root Cause Analysis
Primary Triggers
- Blank Description: The campaign registration form asked for a description of the opt-in process, and you wrote "See attached" or nothing at all. The script must be visible in the text field.
- Vague Process: Writing "We ask the customer if they want texts" is insufficient. Carriers require the exact wording used to ensure all legal disclosures are spoken.
- No Written Confirmation: For verbal opt-ins, carriers expect you to mention how that consent is recorded (e.g., call recording or Double Opt-In SMS).
Required Elements
| Element | Required Language | Rationale |
|---|---|---|
| Consent Question | "Do you agree to receive SMS..." | Must be an explicit question, not a statement. |
| Brand Name | "...from [Your Brand Name]..." | Consumer must know who is texting them. |
| Frequency/Fees | "...msg frequency varies. Std rates apply." | Mandatory compliance disclosures. |
Step-by-Step Remediation
Draft the Verbal Script
Create a short, compliant script that your staff will read. It must include the Brand Name, purpose of messages, and fee disclosure.
✓ Compliant Script
"Would you like to receive appointment reminders via text from Dr. Smith? Message frequency varies and standard message and data rates may apply."
✗ Non-Compliant Script
"Can we get your number for the system?"
(Missing brand, intent, and fee disclosure.)
Paste Script into "Call-to-Action" Field
Go to your campaign registration. Locate the "Call-to-Action / Message Flow" description field. Paste your script there, prefaced with: "Verbal Opt-in Script:"
Describe the Record Keeping
Add a sentence explaining how you prove this happened.
Example: "If the customer says Yes, the agent checks the 'SMS Consent' box in our CRM, which triggers a Double Opt-In confirmation text."
Carrier-Specific Requirements
T-Mobile
- Strong preference for Double Opt-In (DOI) when initial consent is verbal.
- If you don't use DOI, you must be prepared to provide call recordings in case of a consumer complaint.
AT&T
- Strictly requires the verbal script to be provided in text format within the registration form. Attachments are often ignored by automated vetting layers.
MyTCRPlus Tools That Can Help
Consent Form Builder
Even for verbal flows, having a backup digital form (e.g., on a tablet) is safer. Generate one here.
Use This Tool →Audit Documentation Generator
Create a printable "POS Script Card" for your employees to ensure they read the compliant text every time.
Use This Tool →Pre-Resubmission Checklist
- I have written out the exact script in the description field.
- The script includes the Brand Name.
- The script mentions "message and data rates may apply."
- I have explained how the agent records the "Yes."
- I have confirmed my sample messages include the Double Opt-In confirmation (if used).
Common Mistakes to Avoid
❌ "We ask for permission"
Summarizing the process ("We ask them") instead of providing the script ("Do you agree...") is the #1 cause of this rejection.
❌ Forgetting Fee Disclosure
Verbal scripts must still include the legal disclaimer "Standard rates may apply." It feels awkward to say, but it is required for compliance.
Expected Timeline
This guidance provides general information about 10DLC compliance requirements. Verbal consent carries unique evidentiary challenges in the event of a TCPA lawsuit. Organizations should consult legal counsel to determine if verbal opt-in is appropriate for their risk profile. MyTCRPlus does not provide legal advisory services or regulatory representation.