CTA Flows Non-compliant

Why This Rejection Happens

This rejection means the entire process (flow) a user takes to sign up is contradictory, confusing, or does not match what you described in the "Campaign Description." The vetting agent tried to follow your instructions to find the opt-in but got lost or found a different process.

• Description says "Text JOIN to 12345" but the website says "Fill out this form."
• Screenshots show a desktop view, but the URL provided is a mobile app download link.
• The opt-in flow is broken (e.g., submit button doesn't work).
• Mixing up "Keyword" flow with "Web Form" flow in the description.

Root Cause Analysis

Primary Triggers

• Narrative Disconnect: You copy-pasted a generic description ("Users opt in via web") but your actual method involves a paper form at a kiosk. The story doesn't match the evidence.
• Keyword Confusion: You selected "Keyword" as the opt-in type, but your Call-to-Action image shows a web form. You must select the type that matches your primary evidence.

Flow Consistency Check

Step-by-Step Remediation

Rewrite the "Opt-in Flow" Description

Stop using generic templates. Write a literal step-by-step guide for the vetting agent.

Match Evidence to Story

If you wrote the steps above, ensure the screenshot/URL you provide actually shows exactly that page. If the screenshot shows a different page (like a login screen), you will be rejected again.

Pre-Resubmission Checklist

• My description matches my screenshots 100%.
• I have selected the correct "Opt-in Type" dropdown.
• The flow is logical and functional (no dead ends).

Fix It Faster

Validate your description logic.

Need a Flow Diagram?

Sometimes a visual diagram helps approval. We can create one for you.

What reviewers check for code 861

The call to action (CTA) is every place a consumer is invited to opt in: web forms, keyword ads, signage, receipts, QR codes and checkout pages. Reviewers check that each CTA is publicly accessible and contains the full CTIA disclosure set in close proximity to the opt-in action. A CTA that is behind a login, only described in words, or missing any single disclosure fails vetting.

For code 861 (CTA Flows Non-compliant), the missing piece is the full disclosure set. Every opt-in point needs the complete disclosure set in one place: the brand name, a description of the messages, message frequency, "Msg & data rates may apply", HELP instructions, STOP instructions, and links to the privacy policy and SMS terms. Missing any one of these, or spreading them across separate pages, fails review.

Where code 861 comes from

Code 861 is a vetting rejection reason applied during brand or campaign review and passed back to you by your CSP. It identifies the specific deficiency the reviewer found, so fixing exactly that item is the fastest route to approval. It is marked High severity: it blocks approval, but it is fully fixable by correcting the submission and resubmitting.

Example: call to action for a restaurant group

The example below uses a fictional restaurant group, Saltbox Kitchen, to show the difference between a submission that triggers code 861 and one that passes.

Rejected:

Text SALTBOX to (555) 349-5521 for updates!

Approved:

Text SALTBOX to (555) 349-5521 to get reservation confirmations and weekly specials from Saltbox Kitchen. Up to 4 msgs/month. Msg & data rates may apply. Reply HELP for help. Reply STOP to opt out. Privacy Policy: saltboxkitchen.com/privacy | SMS Terms: saltboxkitchen.com/sms-terms

Fix and verify before resubmitting

1. List every CTA location in the campaign and provide a public URL or screenshot for each.
2. Add the full disclosure set where code 861 flagged it, using the approved wording for Saltbox Kitchen's program shown above.
3. Confirm each CTA shows the full disclosure set, not only the primary website form.
4. For printed or in-store CTAs, upload a photo or proof that shows the disclosure text legibly.
5. Remove pre-checked boxes and any language making consent a condition of purchase.
6. Re-test links from the CTA to the privacy policy and SMS terms.
7. Resubmit with a note that references code 861 and quotes the corrected full disclosure set.

Sample resubmission note

Many CSPs let you add a note for the reviewer when you resubmit. A short, specific note shows what changed and speeds up the second review. Example for Saltbox Kitchen:

Saltbox Kitchen corrected the deficiency reported as code 861 (CTA Flows Non-compliant). Changes made: list every CTA location in the campaign and provide a public URL or screenshot for each; add the full disclosure set where code 861 flagged it, using the approved wording for Saltbox Kitchen's program shown above; confirm each CTA shows the full disclosure set, not only the primary website form. All URLs, keywords and auto-replies were re-tested from an external network before this resubmission, and the campaign text now matches the live opt-in exactly.

Common mistakes that keep code 861 coming back

• Showing some disclosures on the form and the rest only in the terms page.
• Describing the opt-in in the campaign but providing no public page or attachment that shows it.
• Using different wording in the campaign than on the live opt-in.
• Fixing the main web form but leaving signage, receipts or keyword ads unchanged.

Related rejection codes

• Code 803: Website Missing Opt-in Language
• Code 30893: Invalid Sample Messages
• Code 2132: Opt-in Instructions Insufficient
• Code 2125: Webpage Missing Opt-in Form
• Code 3009A: CTA Missing Phone Number
• Code 852: Terms and Privacy Links Missing
• Code 3011A: CTA URL Missing or Inaccessible
• Code 3010A: CTA Missing Age Gate

Frequently asked questions about code 861

Does code 861 mean the whole campaign is non-compliant?

No. Code 861 points to one gap: the full disclosure set in your call to action. Fix that gap, check the rest of the submission against the same checklist, and resubmit. Reviewers often list only the first deficiency they find, so a full self-check prevents a second rejection.

Where exactly should the full disclosure set appear?

Keep the disclosure in the same visual block as the opt-in button, keyword or checkbox. Every opt-in point needs the complete disclosure set in one place: the brand name, a description of the messages, message frequency, "Msg & data rates may apply", HELP instructions, STOP instructions, and links to the privacy policy and SMS terms.

Do I fix my live call to action or only the campaign text?

Every live call-to-action location, plus the campaign's description of them. A single non-compliant CTA is enough to fail.

Legal Disclaimer: Code 861 requires accuracy in description. Misrepresenting your data collection method to carriers can result in campaign suspension.

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