TCR Vetting Systems Operational
Code 2116High

Opt-in Form Missing Fee Disclosure

Why This Rejection Happens

The disclosure text on your web-based opt-in form (checkbox, footer, or signup widget) does not warn the consumer about potential carrier fees. You must include the phrase "Message and data rates may apply" (or "Standard rates apply") next to the consent button.

Common Triggers: Forms that omit the fee warning because "texting is free" or due to design constraints.

Root Cause Analysis

Primary Triggers

  • Design Oversight: The legal text was shortened to fit a small mobile screen or popup, and the fee disclosure was cut.
  • Obsolete Templates: Using an old SMS plugin or form template that hasn't been updated to reflect current 10DLC requirements.
  • Misunderstanding: Believing that because the brand doesn't charge for the text, no fee disclosure is needed. The disclosure refers to carrier charges.

Required Elements

ElementRequired LanguageRationale
Fee Disclosure"Message and data rates may apply"Mandatory warning about potential costs to the user.
Alternative"Standard rates apply"Acceptable shorthand, though full phrase is better.
PlacementVisible on FormMust be seen before clicking submit.

Step-by-Step Remediation

Review Your Web Form

Go to your signup page. Read the small print. Does it mention rates/fees? If not, you must add it.

Add the Required Phrase

Insert "Message and data rates may apply" into the disclaimer text near the submit button.

✓ Compliant Disclosure

"I agree to receive SMS alerts from [Brand]. Msg frequency varies. Message and data rates may apply."

✗ Non-Compliant Disclosure

"Sign up for free updates."

(Even if your service is free, carrier rates might not be.)

Update Your Submission

If you provided a URL, ensure the live site is updated. If you provided a screenshot, upload a new one showing the fixed text.

Carrier-Specific Requirements

T-Mobile

  • Strictly requires the fee disclosure to be "clear and conspicuous." It cannot be hidden in a tooltip or a linked Terms page. It must be visible on the form.

AT&T

  • Checks for the specific phrase "rates may apply." Avoid creative variations like "carrier charges might happen." Stick to the standard legal text.

MyTCRPlus Tools That Can Help

Generates compliant HTML with the "Msg & Data rates may apply" text pre-inserted.

Screenshot Hosting Service

Host your updated form screenshot to prove compliance to the vetting team.

Pre-Resubmission Checklist

  • The form text includes "Message and data rates may apply" (or similar).
  • The text is visible without clicking a link.
  • The disclosure is near the "Submit" or "Subscribe" button.
  • I have updated the live website or screenshot.

Common Mistakes to Avoid

❌ "Free SMS" Claims

Never label your SMS alerts as "Free" on the signup form unless you are 100% certain (which is impossible for 10DLC). Always warn that rates may apply.

❌ Hiding it in the Footer

Placing the fee disclosure in the website footer (far away from the form) is not compliant. It must be grouped with the opt-in action.

Expected Timeline

This guidance provides general information about 10DLC compliance requirements. Fee disclosures protect businesses from consumer complaints regarding unexpected carrier charges. Organizations should ensure their forms include standard fee warnings regardless of their own pricing model. MyTCRPlus does not provide legal advisory services or regulatory representation.

Need Help Fixing This Issue?

// Specs

Code
2116
Severity
High
Category
10DLC / TCR
Status
Verified 2026

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