Compliance Posture FAQ
Answering the questions operators bring once they’ve read the posture map: I enabled the toggle — why is nothing blocked yet? Why did a number only on the federal DNC read back clear? What does the platform actually enforce for me, and what is mine to own? Each answer below points at the deep page that owns the topic. Read this page for the mental model; read the linked page before you build on it. The first block — the one-line questions, a quick index — covers the short “what does X mean / does X block?” lookups operators land on from help-search, each pointing at the deep page that owns it. The platform-level questions follow it.The one-line questions — the Q&A index
What does fail-open mean here?
Fail-open means the gate passes traffic when its input cannot be resolved, rather than blocking. Quiet hours, DNC, RND, the STIR/SHAKEN attestation floor, and the preference center all fail open by design: a timezone-unresolved non-US recipient passes under the defaultskip policy, an unsynced federal feed renders solely-federal
numbers clear as no_data, and a failed attestation-ownership lookup
signals C instead of blocking the call.
Every gate ships off / open, and no gate blocks while its input is
unreadable — you tighten from an open default, never loosen from a
restrictive one. The rows marked Fail-open on
the posture map list the surfaces, and
Send Gates has the exact per-gate behaviour.
What is fail-closed by design?
Fail-closed means the gate blocks when enabled criteria catch, or when a required approval is missing. Sender-ID registration blocks regulated A2P SMS until the country’s entry isapproved; a suppression
entry drops the address pre-dispatch regardless of entry point; the
US state mini-TCPA overlays hard-block campaign and dialer voice on the
most-restrictive-wins rule; and HIPAA mode refuses PHI sends with
422 HIPAA_BAA_REQUIRED until the BAA is executed. The opt-in RMD
origination guard, when you turn it on, blocks outbound voice at
origination when your filing is deficient.
The pattern holds from the platform level down: whatever protects a
recipient or a regulator blocks; whatever protects your own list
hygiene is opt-in and fails open. The rows marked Fail-closed on
the posture map enumerate the surfaces
— do not wire a recipient-protection gate as fail-open.
Where do I see my gates?
Two places. In the dashboard, the Settings → Compliance group of routes holds every writable gate; over the API, theGET /api/v1/settings/compliance/* reads report each toggle’s current
value — unknown-consent marketing policy, consent default policy,
country allowlist, inbound country gate, fraud caps, channel-rate
overrides, AI-turn audit, and the inbox-AI privacy gates. The
GET /compliance/health scores and the
GET /compliance/quiet-hours/preview endpoint are the read-only
surfaces for the same posture.
Verify every write with the paired GET — never assume a PUT took.
The Settings → Compliance surface is mapped row by row on
the posture map, and
Configure Your Tenant’s Posture Before the First Send
walks it in day-one order.
How many minutes to set up a posture?
Two flips for either of the two most common postures. For “Marketing to US mobiles”: (1) enable thesms channel on the org
quiet-hours gate, and (2) bulk-import any legacy opt-out list with
POST /compliance/suppression-list/import while you complete brand
and campaign registration — US long-code traffic degrades without it
regardless of gate posture. See
Posture A.
For “Healthcare appointment reminders”: (1) execute the BAA and enable
HIPAA mode (PUT /api/v1/settings/hipaa — the mode refuses to enable
until then), and (2) close the inbox-AI gates with
PATCH /api/v1/settings/compliance/inbox-ai-privacy
(auto_categorize: false, auto_summarize: false), because both ship
on and send inbound message bodies to a third-party LLM. See
Posture D
and the full
HIPAA onboarding walkthrough.
How do I audit what a gate did?
Read the auditable record — Orbit logs every gate decision, covering consent decisions, suppression entries, scrub results, certifications, and the owner-only settings flips in the org audit log. For a specific send the record answers why it was held or passed: quiet-hours holds report the resolved window and the preview endpoint thenext_allowed_at timestamp, and voice blocks report
outside_state_window / state_blocked_day reasons so state holds
are separable from federal ones.
When the audit question outgrows gate-level rows: one-click,
framework-mapped packs on
Evidence Binder (SOC 2 / ISO 27001 /
GDPR / HIPAA), verbatim AI-turn records on
AI Turn Audit (off by default — it
persists multi-year verbatim PII, so enable it per written policy), and
the GDPR Art. 33/34 clock on
Breach Incident Register.
Is this legal advice?
No. The gates and their audit trail are tenant-owned controls, and the responsibility for choosing a posture — and for deciding whether a posture is adequate — stays yours. Orbit is the conduit and the ledger; it does not decide that a send is compliant, does not file with a regulator for you, and does not send customer notices for you. Which laws apply to your traffic depends on where you and your recipients are and what you send. Confirm your obligations with qualified counsel before you rely on any posture described here.Are any of these gates platform-mandatory?
No — with exactly one exception. Compliance controls are tenant-owned: Orbit gives you the control surface (gates, windows, scrubs, registries), each gated control ships off, and it enforces what you set rather than mandating a posture. The single exception is the US TCPA federal voice dialing window: campaign and dialer voice to US (+1) recipients outside the 8 AM–9 PM recipient-local window is hard-blocked (422 TCPA_FEDERAL_DIALING_WINDOW_BLOCKED)
with no tenant toggle, no per-organization bypass, and no fail-open on
a timezone-unresolved recipient. The 1,500 per-call statutory
penalty is not the tenant’s to waive.
Stricter state mini-TCPA overlays (Florida’s Sunday ban, Mississippi’s
7:30 PM close, and the Oklahoma/Louisiana/Alabama/West Virginia
windows) sit on top of that federal rail and are likewise not a
tenant knob. Everything else — quiet hours, DNC, RND, STIR/SHAKEN
floors, HIPAA mode, DSAR, KYC gates — is yours to flip, default open.
The full asymmetry list is on
What is not tenant-toggleable.
What does the compliance-health score never block?
Everything on the health surface is read-only: it reports your posture, it never changes it.GET /compliance/health (plus
/health/numbers and /health/campaigns) blends consent coverage,
opt-out velocity, STOP-reply rate, and carrier rejections into a 0–100
score with a ranked warnings array — it never blocks a send,
suppresses a contact, or gates your traffic. Use it as an
early-warning read: which sender a carrier is about to throttle,
before the traffic degrades. The same rule holds for the quiet-hours
preview endpoint — it answers “would this send be held?” without
holding anything. See
Compliance Health Scores.
I enabled quiet hours — does that protect my campaign sends?
Yes, if either of the two knobs is set. Campaign, drip, and journey sends are evaluated against the campaign fallback window (set in Settings → Campaign limits, orPUT /api/v1/campaigns/quiet-hours/settings); if you never set one,
they fall back to the platform default 21:00–09:00. For 1:1 and
ad-hoc traffic, protection only exists where a channel is enabled on
the org gate (settings → quiet_hours.<channel>.enabled). So “quiet
hours on” must mean at least one of: a channel enabled on the org
gate, or a fallback window your campaign traffic inherits. Check
GET /compliance/quiet-hours/preview before a rollout to see exactly
what would be held and until when. The two-knob model is on
Quiet hours configuration.
Note again the one platform exception above: campaign and dialer voice
to US recipients is always held by the federal 8 AM–9 PM window even
with both toggles off — see
Send Gates.
Is Sender-ID approval instant?
No. Registering a Sender ID in Orbit submits it into the compliance workflow, but final approval is granted by the regulator or carrier in each country — not by the platform. A country entry sits atpending (or returns rejected with a reason) until that external
decision lands, and A2P SMS into a country that requires a registered
Sender ID is fail-closed: blocked until that country’s entry reads
approved. Plan lead time — some markets take days to weeks — and
attach the country’s KYC documents up front to avoid a re-submission
loop. See Sender-ID Registration
and the recovery workflow on
Troubleshoot a pending number or Sender ID.
The same external-lead-time pattern applies to US 10DLC (brand and
campaign review, 1–5 business days typical, per-carrier statuses
tracked separately) and to regulated-country number purchases, which
idle at pending_compliance until an approved compliance profile is
attached.
Will the DNC scrub work out of the box on SaaS?
Partially — and the gap is the operator question this FAQ exists for. The DNC chain scrubs your own layers (contact DNC flags, DNC list, suppression, consent opt-outs) plus the platform list as soon as you opt in withdnc_sync_enabled. The federal/state/TCR feed
layer only backs the check once a snapshot is synced, and on the
Devotel-hosted SaaS the TCR feed is only populated when the operator
iconectiv TCR partner credentials (DEVOTEL_TCR_API_KEY /
DEVOTEL_TCR_PARTNER_ID) are configured — if either is unset the
connector no-ops and no feed arrives. Until it does, two consequences
follow:
GET /compliance/dnc/checkreturns403 DNC_SYNC_NOT_ENABLEDuntil you opt in, and even after opting in it returnsfederal_feeds_synced: falseon every response — a number only on the FTC federal register reads back clear in that state. Never treat a clear verdict as federal safe-harbor unlessfederal_feeds_synced: true.GET /compliance/rnd/checkdegrades similarly: until the FCC feed is synced, every verdict isno_data(no safe harbor), and enablingrnd_scrub_enabledis refused with a409until the feed is connected.
Which controls fail open and which fail closed?
Condensed from the posture map — the column to internalize before you trust a toggle:
The pattern: anything that protects a recipient or a regulator
fails closed or is platform-level; anything that protects your own
list hygiene is opt-in and fails open. The deep pages behind each
row are on Send Gates.
Does this page cover the EU AI Act’s Annex III high-risk tier?
No — and the split follows the same tenant-owned pattern as everything else on this page. Orbit ships the Article 50 transparency surface: AI-interaction disclosure notices, AI-generated-content marking, and exportable evidence, configured per workspace on EU AI Act — Article 50 Transparency. Annex III is a separate tier: the high-risk use cases (for example emotion recognition, biometric categorization, and the other listed classes) carry risk-management, data-governance, technical-documentation, and conformity-assessment obligations on a later timeline than the transparency obligation. The classification — whether your deployment falls into an Annex III use case at all — is yours to make with qualified counsel; the controls either way stay tenant-owned, exactly as with the gates above. If an Annex III use case does apply, Article 50 transparency still applies on top.Is any of this legal advice?
No. Orbit is the conduit and the ledger: it carries your sends, enforces the gates you set, and keeps the auditable record (consent decisions, suppression entries, scrub results, certifications). It does not decide that a send is compliant, does not file with a regulator for you, and does not send customer notices for you. The posture you choose is additive from an open default, and the responsibility for choosing it stays yours. Confirm your obligations with qualified counsel.Related references
- Your Tenant Compliance Posture: The Toggle Map — the full map this FAQ condenses.
- Compliance Approval Timelines & Trigger Runbooks — the platform-paced vs external-paced timeline table and the trigger-event runbook routes, deep-linked per topic.
- Send Gates — every send-time gate and its exact gate behaviour.
- DNC Scrubbing — sources, freshness, and the fail-open caveat.
- Compliance Health Scores — the read-only signal layer.
- EU AI Act — Article 50 Transparency — the disclosure surface, plus the out-of-scope Annex III pointer.
- Troubleshoot a pending number or Sender ID — gated assets stuck behind external approval.
- Platform FAQ — non-compliance questions (authentication, billing, channels, webhooks).