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Compliance FAQ: sends, calls, and registration gates

This is the routing layer for compliance questions: a support reply, a first-time tenant setup, a “which gate fired?” lookup. Each answer is one to three sentences ending in a deeplink to the page that owns the topic — read this page to route the question, read the linked page before you act on it. Nothing here is a claim source; the linked page is always authoritative. For the mental model behind the routing table — which gates fail open, which fail closed, and who owns each control — read the Compliance Posture FAQ and the posture map.
This page describes Orbit’s platform controls. It is not legal advice. Which laws apply to your traffic, and what posture is adequate, depends on your jurisdiction, your recipients, and what you send. Confirm with qualified counsel.

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10DLC & toll-free verification

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My 10DLC campaign is pending. Can I send?

No. US long-code A2P traffic is fail-closed: sends are blocked until the campaign is approved by the carriers. Brand and campaign review typically takes 1–5 business days, and per-carrier statuses are tracked separately. See the full lifecycle on 10DLC registration and the parallel toll-free verification track for TF numbers.

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What is the difference between a brand rejection and a campaign rejection?

A brand rejection is about your identity payload (legal name, EIN, website); a campaign rejection is about the use-case description and message samples. Rejected content fixes mean re-submission, while a low vetting score calls for a re-vet — the remedy differs, so decode the rejection code first on 10DLC rejections, re-vetting, and the post-approval lifecycle.

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Sender ID & country requirements

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Which countries require sender pre-registration?

Run GET /api/v1/compliance/country-requirements: the registration field on each country entry reads none, recommended, or required, and where it reads required you must have an approved Sender-ID entry before A2P SMS delivers. The per-entry workflow (pending → approved, or rejected with a reason) is on Sender-ID Registration.

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I got SENDER_ID_NOT_REGISTERED on a send. What does it mean?

The from value is a custom alphanumeric sender ID with no registration row on your account — this gate is fail-closed. Register it under Settings → Sender IDs, or send with the platform default sender or one of your phone numbers. The full diagnosis (including SENDER_ID_NOT_APPROVED and the transient SENDER_ID_CHECK_UNAVAILABLE) is on Troubleshooting: SENDER_ID_NOT_REGISTERED.

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STIR/SHAKEN

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Why is my outbound call signed at attestation level C?

C means the platform cannot verify ownership of the calling number, so it attests “the gateway can’t tell where this call originated” — which exposes the call to spam-likely treatment downstream. Register a delegate certificate to lift covered numbers from C to B (partial). Details on Attestation posture and Troubleshooting: attestation stuck at C.

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Should I register a delegate certificate?

Yes, if you bring your own verified numbers (BYON): registering an ATIS-1000092 delegate certificate lifts the numbers it covers from C to B. A self-registered certificate can only ever reach partial (B) — full attestation (A) on a number you did not port into Orbit would be spoofing, and the registry will never mint that. The registry lives at /compliance/attestation/delegate-certs; see Attestation posture.

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TCPA & quiet hours

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What is the one gate I cannot turn off?

The US TCPA federal voice dialing window: campaign and dialer voice to US (+1) recipients outside 8 AM–9 PM recipient-local is hard-blocked with 422 TCPA_FEDERAL_DIALING_WINDOW_BLOCKED — no tenant toggle, no per-organization bypass, and no fail-open on a timezone-unresolved recipient. The 500–500–1,500 per-call statutory penalty is not the tenant’s to waive. Read The TCPA federal voice guard; the stricter state overlays on top of it are on US state calling windows.

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Can a tenant lift the emergency-call block?

No. Emergency numbers (911 / 112 / 999 / 000) always route on Orbit, and no tenant gate can block them — the same stance as the federal TCPA window. Details and the address-registration duty for emergency routing are on Emergency calling.

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How do state mini-TCPA overlays interact with the federal window?

Stricter state overlays — Florida’s Sunday ban, Mississippi’s 7:30 PM close, and the Oklahoma / Louisiana / Alabama / West Virginia windows — sit on top of the federal rail on a most-restrictive-wins rule and, like the federal window, are not a tenant knob. The overlay map is on US state calling windows; the blocked-call codes (TCPA_STATE_DIALING_WINDOW_BLOCKED, TCPA_DIALING_WINDOW_BLOCKED, TCPA_TIMEZONE_UNKNOWN) are decoded on Troubleshooting: state mini-TCPA blocked calls.

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Opt-out & suppression

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Does a STOP on SMS also block voice calls?

By default, yes. A STOP keyword on a phone number records the opt-out with the all channel scope, which suppresses every channel reachable on that number — and the voice and dialer gates honour phone suppressions, so the number stops receiving calls too. Scope semantics (all vs a specific channel) and recovery are on Opt-Out & Suppression Lists.
Use the CSV import (POST /compliance/suppression-list/import) when you are backfilling a legacy opt-out list — it returns per-row results with intra-file deduplication. Use the Consent API for live per-event consent and revocation. Both feed the same suppression chain, so a suppressed address is dropped pre-dispatch regardless of entry point. See Opt-Out & Suppression Lists. If your DNC pre-flight check returns 403 DNC_SYNC_NOT_ENABLED, the fix is on the DNC check gated troubleshooting page.

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DNC & RND scrubbing

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Why is DNC off by default?

Because DNC is a list-hygiene control, and list-hygiene controls fail open by design: you opt in with dnc_sync_enabled. The important caveat — on the hosted platform a clear verdict only counts as federal safe-harbor when federal_feeds_synced: true; until the federal feed is synced, a number listed only on the FTC register reads back clear. Sources, freshness, and the check endpoint are on DNC Scrubbing; the gate error itself is on Troubleshooting: DNC_SYNC_NOT_ENABLED.

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BAA & HIPAA

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Why did my send throw HIPAA_BAA_REQUIRED?

HIPAA mode is enabled for your organization and the send’s audience or content matched PHI — the mode refuses PHI-bearing sends with 422 HIPAA_BAA_REQUIRED until a Business Associate Agreement is executed, and HIPAA mode itself will not enable until then. The gate list is on Send Gates; the two recovery paths are Troubleshooting: HIPAA enable blocked (403) and Troubleshooting: HIPAA_BAA_REQUIRED (422).

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The one platform-mandated control

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Is there any compliance control the platform owns outright?

Exactly one: the US TCPA federal voice dialing window described in the TCPA section above. Every other compliance control — quiet hours, DNC, RND, STIR/SHAKEN floors, HIPAA mode, DSAR, KYC gates, sender-ID registration — is tenant-owned, ships off or open, and fails open on unresolvable input. The full asymmetry list is on the posture map, and the guard itself is on the TCPA federal voice guard.