TCPA Opt-Out Requirements: Honoring STOP and Every Other Way People Say No

The table compares the rule in force on the date of this review, 12 November 2026, with the amended text the FCC published on 26 October 2026. The amended rule states that it becomes effective 30 days after Federal Register publication. Nelson Mullins and other firms calculate that date as 25 November 2026.

The right-hand column comes from the amended rule text in the Federal Register public inspection copy.

The rule at 47 CFR 64.1200(a)(10) names three methods that are reasonable by definition: an automated, interactive voice or key-press opt-out mechanism on a call, a reply to a text with one of the standard words, and a request made through a website or telephone number the caller provides for opt-outs.

As the rule stands today, the list is a floor. A person may revoke using words other than the seven, and the caller must treat the reply as a revocation if a reasonable person would understand it that way. A message such as please stop texting me fits that description. The current text also says a caller cannot designate an exclusive means of revoking consent.

Paragraph (a)(11) covers everything off the list, such as a voicemail or an email. Using a method that is not listed creates a rebuttable presumption that consent was revoked once the person produces evidence that the request was made. The caller can try to show, on the totality of the circumstances, that the request was not conveyed in a reasonable manner.

The ten-business-day ceiling appears in two places. Paragraph (a)(10) applies it to revocations of consent for autodialed and prerecorded calls and texts. Paragraph (d)(3), the internal do-not-call rule for telemarketing, says a request must be recorded and the number placed on the list at the time the request is made, and honored within a reasonable time not to exceed ten business days.

The phrase reasonable time does real work. The research behind this post found firms describing the base rule as in force since 11 April 2025.

The period may shorten. In the further notice published alongside the October 2026 order, the FCC asks whether to reduce the deadline, with seven business days given as an example, according to Nelson Mullins. Comments are due 25 November 2026 and replies 28 December 2026. Nothing has been adopted.

The order is FCC 26-67 in CG Docket No. 02-278. The Federal Register synopsis says it was adopted on 30 September 2026 and released on 1 October 2026. The public inspection copy was scheduled for publication on 26 October 2026 and states an effective date 30 days after publication. The FCC declined a request to extend that date by up to twelve months.

The first change is the exclusive method. The amended paragraph (a)(10) says callers may designate any of the three listed methods as the exclusive means to revoke consent, and that a caller who does so is not required to process requests made by any other means. The caller must clearly and conspicuously disclose the designated method on the call or in the text. A text sender that designates reply words can satisfy the disclosure by including at least one of the seven words in each message, as long as it recognizes all seven.

The second change is scope. A revocation made in response to a call or text that contains an advertisement or constitutes telemarketing revokes consent to all future advertising and telemarketing calls and texts from that caller. A revocation made in response to an informational call or text may be interpreted as applying only to the specific category of informational message it answered. The FCC's example is a customer who stops payment reminders and would otherwise also lose fraud alerts and appointment reminders.

One point needs care. The amended rule text lets callers designate exclusive methods without limiting that sentence to informational messages. The FCC's discussion adds that the change does not alter the existing opt-out methods specified for calls made under an exemption or calls that include an advertisement or constitute telemarketing, and gives the automated opt-out mechanism required on prerecorded telemarketing calls as an example. Some early summaries in our research notes read the exclusive-method option as unavailable for marketing messages. Read the order itself, and ask counsel, before relying on a single designated method for marketing traffic.

The history explains why older guidance conflicts with newer guidance. The FCC adopted its revocation rule in 2024. One part of it would have required a caller to treat a stop request on one type of message as revoking consent for all future robocalls and robotexts on unrelated matters. The October 2026 order records that a broad range of commenters, utilities among them, said a customer who stopped one reminder would lose alerts they wanted.

The FCC's Consumer and Governmental Affairs Bureau delayed that part to 11 April 2026 in order DA 25-312, and again to 31 January 2027 in order DA 26-12, according to Nelson Mullins. The October 2026 order then replaced it. The Federal Register text says the modified rule goes into effect 30 days after publication and supersedes the delayed effective date that had been extended to 31 January 2027.

Paragraph (a)(12) says a text confirming a revocation request does not violate the consent rules as long as it merely confirms the request and does not include any marketing or promotional information. If it is sent within five minutes of receipt, it is presumed to fall within the person's prior express consent. If it takes longer, the sender has to show that the delay was reasonable.

The current text of (a)(12) also lets the confirmation ask whether the person meant to stop all categories of messages, with the sender stopping everything that needs consent unless the person clarifies. The amended (a)(12) in the October 2026 publication is shorter and does not carry that sentence. Nelson Mullins lists confirmation messages, and letting texters ask which category a person meant, among the questions the further notice asks. Treat clarifying questions as an open point until the FCC acts.

One-way messaging has its own line in the rule. A sender whose texting system cannot receive replies must say so clearly in each text and provide reasonable alternative ways to revoke consent in each text.

The internal do-not-call rule says that, absent a specific request to the contrary, a residential subscriber's request applies to the particular business entity making the call, or on whose behalf the call is made, and does not apply to affiliated entities unless the consumer reasonably would expect them to be included given the identification of the caller and the product advertised. The October 2026 order repeats that reminder for telemarketers.

Channel matters too. The amended rule says a revocation in response to a marketing call or text revokes consent to all future calls or text messages that contain an advertisement or constitute telemarketing from that caller. A person who replies stop to a promotional text has, on that wording, also stopped promotional robocalls.

Sharing the request is restricted. Under paragraph (d)(3), a person or entity making a call on behalf of a seller needs the consumer's prior express permission to share or forward a do-not-call request to anyone other than the seller or its affiliates. In practice the request has to travel from the vendor that received it to the seller, and from the seller to every other vendor that contacts the same person.

Florida's telephone solicitation statute ties the opt-out to the right to sue. Before bringing an action over text message solicitations, the called party must reply STOP to the number that sent them. The solicitor then has 15 days to stop, apart from one confirmation text. The person may sue only if they have not consented and the solicitor keeps texting more than 15 days after the notice.

Pennsylvania's Act 47 of 2026 uses the same seven words as the FCC. It says a person may state the intent to stop receiving telephone solicitation text messages by responding stop, quit, end, revoke, opt out, cancel or unsubscribe in reply to an incoming text.

Federal private enforcement is narrower for texts than it was. In Steidinger v. Blackstone Medical Services, decided 14 July 2026, the plaintiffs said they kept receiving marketing texts after replying STOP. The Seventh Circuit held that the private Do Not Call claim in 47 U.S.C. 227(c)(5) does not cover text messages, and noted that spam messages may still be curbed through agency action. That ruling binds federal courts in three states and does not change what the FCC's rule requires.