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The FCC's TCPA Opt-Out Order: Revoke-All Narrowed, Exclusive Methods Allowed
What did the FCC change about TCPA opt-outs in September 2026?
Short answerIt narrowed revoke-all, allowed exclusive opt-out methods and left the deadline alone, in an order (FCC 26-67) adopted on 30 September 2026 that is not in force yet. Once it takes effect, an opt-out from an informational robocall or text may be treated as covering only that category of informational message, while an opt-out from marketing still ends all of the caller's marketing. A caller may designate an exclusive opt-out method (an automated voice or key-press opt-out, a reply with one of the seven keywords, or a website or number it names) if it discloses that method clearly on each call or text. And the 10-business-day deadline stays, though the FCC is asking whether to shorten it. The changes take effect 30 days after publication in the Federal Register, replacing the revoke-all waiver that runs to 31 January 2027.
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At its 30 September 2026 open meeting the FCC adopted FCC 26-67, with Chairman Carr and Commissioners Gomez and Trusty approving, and released it on 1 October. It is the fix for the "revoke-all" rule the FCC had delayed twice since 2025. It pairs a narrower revoke-all rule with a reversal of one piece of the 2024 rules, which barred callers from naming an exclusive way to opt out: once the new rules take effect, callers may say how opt-outs must be made. They are adopted but not yet in force.
What changes once it takes effect
- Revoke-all is narrowed for informational messages. When a consumer opts out in response to an informational robocall or text, meaning one that is not an advertisement and not telemarketing, the caller may treat the opt-out as covering only that category. A bank customer who replies STOP to payment reminders can still receive fraud alerts. An opt-out in response to marketing still ends all of the caller's marketing calls and texts.
- Callers may designate an exclusive opt-out method. Three methods qualify: an automated, interactive voice or key-press opt-out on the call; a reply with one of the seven keywords (
stop,quit,end,revoke,opt out,cancel,unsubscribe); or a website or telephone number the caller names. A caller may designate more than one. The designated method has to be disclosed clearly and conspicuously on the call or in the text itself, and once it is, the caller need not process opt-outs made any other way. A text sender that designates reply texts can disclose just one keyword per text, but must still honor all seven. - Financial institutions get a wider fraud-alert exemption. Their exempt alerts to wireless numbers, about possible fraud or identity theft, data breaches and pending money transfers, may go to a number the customer did not give them directly, if it came from a reliable source: a spouse or other family member authorized on the account, a call the customer made to the institution, or records obtained from another financial institution. The exemption's other limits, such as three messages per event over three days, stay.
What does not change
- 10 business days. The outer limit for honoring an opt-out stays where it has been since 11 April 2025.
- The seven keywords, with one exception. They remain effective in reply to a text unless the sender has designated a different exclusive method, such as a website or phone number, which it must disclose in each text. Calls and texts made under an exemption, and prerecorded telemarketing calls, must still offer the opt-out mechanisms the rules already require for them.
- Any reasonable method, for callers that designate nothing. Without an exclusive method, a caller still has to process opt-outs made by any reasonable means, and a revocation by other routes still creates a rebuttable presumption.
- Marketing opt-outs are total. The narrowing is for informational messages only.
When it takes effect
The rules take effect 30 days after the order is published in the Federal Register, and the FCC will announce the exact date by public notice. As of 6 October 2026 the order had not been published. Its effective date replaces the delayed effective date of the revoke-all portion, which CGB's waiver (DA 26-12) had pushed to 31 January 2027, and the FCC declined a request to set it as late as 12 months after publication. Until they are in force, the current rules apply: consumers may opt out by any reasonable method, no caller may name an exclusive method, and the revoke-all portion stays waived.
What the FCC is still asking about
A further notice of proposed rulemaking, open for comment 30 days after Federal Register publication (replies at 60), asks whether to:
- shorten the 10-business-day window, with seven business days suggested;
- require every text sender to accept opt-outs by reply, ending one-way texting for some or all messages;
- make category-limited revocation conditional on offering a one-step, revoke-all option, and whether an opt-out covers only the number it came from;
- decide how opt-outs apply across a company's affiliates, lines of business and divisions;
- shorten the keyword list, drop the rebuttable presumption, or allow a confirmation call.
None of these is decided. Build for the rules in force, and watch the comment cycle.
What to do now
- Decide whether to designate an exclusive method. It is optional. If you do, every call script and text template needs the disclosure before you rely on it, and your systems must actually capture opt-outs through that method. If it is reply texts, recognize all seven keywords even if your texts name only one.
- Tag informational messages by category if you intend to rely on the narrower reading, so an opt-out can be applied to the right category. Without tagging, treat every opt-out as total.
- Keep the 10-business-day clock. Nothing in the order lengthens it, and the further notice may shorten it.
This is a change to how you process consent, which lives inside your own systems. No external list can tell you who opted out of what. What a scrub covers is the adjacent risk: disconnected numbers, landlines on a mobile campaign and known TCPA litigators, none of whom ever opted out. See the TCPA compliance guide for the full current position.
Frequently asked questions
Does a STOP reply still end every message from the caller?
For marketing, yes: an opt-out in response to a marketing call or text revokes consent to all of that caller's marketing. For informational messages, once the rules take effect, the caller may treat it as covering only the category the consumer was replying to, so a bank customer who opts out of payment reminders can still get fraud alerts. The caller is allowed to read it that narrowly, not required to. Treating it as a full opt-out remains the safer default.
Can I require customers to opt out one specific way?
Yes, once the rules take effect, provided you use one or more of the three methods the FCC lists (an automated voice or key-press opt-out on the call, a reply with one of the seven keywords, or a website or phone number you name) and disclose it clearly and conspicuously on the call or in the text. If you designate reply texts, naming one keyword in each text, such as "Reply STOP to opt out", is enough, but you must still honor all seven. A method another agency's rules set, such as written notice for debt collection, cannot be the exclusive one.
Two limits. Calls and texts made under an exemption, and prerecorded telemarketing calls, must still offer the opt-out mechanisms the rules already require for them. And a caller that designates nothing must keep processing opt-outs made by any reasonable means, exactly as today. Until the effective date, no caller may designate an exclusive method.
Did the 10-business-day deadline change?
No. Opt-outs must still be honored within 10 business days. The FCC's further notice asks whether to shorten it, and a joint letter from bank, consumer and collections groups suggested seven business days, but nothing is decided. See the 10-business-day opt-out clock.
When do the changes take effect?
Thirty days after the order is published in the Federal Register, on a date the FCC will announce by public notice. As of 6 October 2026 it had not been published. Until it takes effect the current rules apply: any reasonable method, no exclusive methods, and the revoke-all portion waived until 31 January 2027.
- FCC -- Report and Order and FNPRM on consent revocation, adopted 30 September 2026 (FCC 26-67)
- FCC -- FCC Votes to Give Consumers More Choice in the Calls They Receive (news release, 30 September 2026)
- FCC -- September 2026 Open Commission Meeting
- FCC -- CGB extends the effective date of the TCPA's consent revocation rule (DA 26-12, 6 January 2026)
- 47 C.F.R. § 64.1200 -- Delivery restrictions (eCFR)