The Federal Communications Commission has adopted amendments to its Telephone Consumer Protection Act rules, which will clarify how consumers can withdraw consent to automated calls and texts. Adopted September 30, 2026, the changes take effect 30 days after Federal Register publication.
Under existing law, consumers may withdraw consent through any reasonable method and plaintiffs often argue that any revocation of consent for any type of text or call applies to all types of texts or calls.
The FCC’s amendments allow callers/texters to designate one or more approved methods as the exclusive way to opt out. Those methods include an automated voice or key-press option, a reply text using recognized opt-out words, or a caller-provided website or telephone number. Callers must clearly and conspicuously disclose the designated method on the call or in the text. Once they do, they may not have to honor requests made through other methods. Without sufficient designation and disclosure, the existing reasonable-method standard continues to apply.
A text sender choosing reply-text opt-outs may disclose just one recognized word, such as “stop.” It must still accept all seven recognized terms: “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” and “unsubscribe.”
The amendments also replace the broader “revoke all” requirement, whose effective date had been delayed until January 31, 2027. That requirement would treat an opt-out from one type of informational message as withdrawing consent for unrelated robocalls and texts from the same caller. Under the amendments, callers may limit an informational-message opt-out to the category that prompted it. A request to stop payment reminders, for example, would not automatically stop fraud alerts. Marketing opt-outs remain broader: a request responding to advertising or telemarketing withdraws consent for all future marketing robocalls and texts from that caller.
Financial institutions also gain more flexibility for certain exempt informational messages, including fraud alerts. Existing rules limit consent for such calls/texts to wireless numbers supplied directly by the customer, but the amendments permit fraud alerts and similar informational calls/texts to numbers provided by authorized family member, a customer’s incoming call/text, or records from another financial institution.
The FCC also contemplates further potential changes, such as: whether to shorten the current ten-business-day maximum for honoring consent withdrawals, requiring reply-text opt-outs instead of allowing disclosed alternatives for one-way texts, and requiring a one-step option to stop all consent-based robocalls and texts. The FCC also raises the issue of how opt-outs should apply across affiliates and business divisions. These proposals are not adopted requirements.
Note that uncertainty and risk remain. Recently, some courts have limited the scope of the FCC’s authority to regulate under the TCPA and it remains to be seen how courts may put these new rules into practice.
Putting it Into Practice. The amendments provide clarity and flexibility in how companies can accept and apply opt-out requests, but uncertainty and risk remain and companies should clearly and reasonably disclose and process opt-outs.