Analysis

The Opt-Out Window Is 10 Business Days. Most Suppression Queues Still Assume 30.

How quickly must I honour a TCPA opt-out?

Short answer

Within 10 business days. The FCC's revocation rules, effective April 11, 2025, set that as the outer limit for honouring a revocation, and cut the old limit for company-specific do-not-call requests from 30 days. Consumers may revoke by any reasonable method, and the words stop, quit, revoke, opt out, cancel, unsubscribe and end are automatically effective.

Checking a whole list? Preview 20 rows of it free →

About NumberBroom. NumberBroom scrubs phone lists before you dial: it removes known litigators, returns each number it keeps with its line type and carrier, and gives every job a dated record of the screening. $0.20 a number, less past 2,000 rows, no subscription.

Where a scrub fits: Meeting the 10-business-day deadline is your own suppression process's job: no outside list knows who opted out of your messages. Numbers you add to the do-not-call list in your NumberBroom account are left out of every list you scrub while signed in.

On this page

Of the TCPA changes in the last two years, this is the one with real operational teeth, and it has had a fraction of the attention paid to the consent rule that was struck down. Effective April 11, 2025, the outer limit for honouring a revocation of consent became 10 business days, and the limit for a company-specific do-not-call request fell from 30 days to the same 10 business days.

Stated that way it sounds like a parameter change. It is not. It is a change that breaks a specific and very common architecture.

Why the queue is the problem

A great many outbound operations handle suppression in batches. Opt-outs accumulate -- from SMS replies, from a web form, from agents dispositioning calls -- and get reconciled into the dialler on a schedule. Weekly is typical. Fortnightly is common. Under the old 30-day limit, a fortnightly reconciliation had about two weeks of headroom and rarely breached.

Under 10 business days, that same fortnightly cycle is already outside the window before anyone touches it. The process did not degrade; the deadline moved underneath it. And because nothing visibly breaks, the failure is silent -- there is no error, no bounce, no alert. The first signal is a demand letter.

Two weeks is now late

10 business days is about two calendar weeks. Any suppression process that runs on a fortnightly or monthly cadence is, by construction, capable of breaching. If reconciliation is manual and someone is on leave, it will.

The channel gap

The second failure mode is structural rather than temporal. Opt-outs frequently arrive on a different system from the one that will place the next call: an SMS platform captures the STOP, and the dialler never learns about it. Both systems are working exactly as designed.

Cross-channel revocation is not the open question: since April 11, 2025, a STOP by text also ends robocalls from that caller, and vice versa. What remains open is whether an opt-out from one type of informational message ends messages on unrelated topics -- the "revoke-all" provision, waived until January 31, 2027, which an order the FCC adopted on September 30, 2026, narrows once it takes effect. That open question is an argument for suppressing more broadly, not less. Suppression costs nothing. A consumer who texted STOP and then got called is not going to find the distinction between channels persuasive, and neither is a jury.

What a compliant process looks like

  • Suppress on receipt, not on schedule. The moment a revocation is captured it should be written to a durable suppression list. Treating this as an event rather than a batch removes the deadline problem entirely.
  • One suppression list, all channels. Voice, SMS and email should read the same list. If they read three lists, you have three chances to fail.
  • Capture the verbatim. Store what the consumer actually said, with a timestamp and channel. When the question later is whether a phrase conveyed a desire not to be contacted, the transcript is the evidence and the presumption runs against you without it.
  • Make it permanent. Revocations must outlive the campaign that produced them. A suppression that lives in a campaign export dies with the campaign.
  • Instrument the lag. Measure the time between revocation and suppression and alert on it. If nobody measures it, nobody finds out it drifted.

Quick check: the 10-business-day clock

Pick an answer to see whether it is right, and why.

1. Opt-outs are collected and reconciled into the dialler every two weeks. Does that keep up with the 10-business-day limit?

Not quite. That was true under the old 30-day limit, which left about two weeks of headroom. Under 10 business days, a fortnightly cycle is already outside the window before anyone touches it.

Right. The process did not degrade; the deadline moved underneath it. Because nothing visibly breaks, the failure is silent, and the first signal is a demand letter. Suppressing on receipt, not on schedule, removes the deadline problem entirely.

Not quite. The failure is silent: there is no error, no bounce, no alert. The first signal is a demand letter.

2. A consumer replies "please stop calling me", which is not one of the seven keywords. Does it count as a revocation?

Not quite. The seven words are treated as automatically effective, but they are a floor rather than a list. Consumers may revoke by any reasonable method.

Right. The seven words are a floor, not a list. A reply text in other words counts if a reasonable person would read it as a revocation, and other routes, such as a voicemail or email, create a rebuttable presumption that consent was revoked.

Not quite. No caller may designate an exclusive opt-out method yet. The order the FCC adopted on September 30, 2026 (FCC 26-67) allows it only once it takes effect, and that change is not in force.

3. A consumer texts STOP. Does that also end robocalls from the same caller?

Right. This part is settled. Since April 11, 2025, a revocation made in any reasonable way covers both robocalls and robotexts from that caller.

Not quite. Cross-channel revocation is not the open question: since April 11, 2025, a STOP by text also ends robocalls from that caller, and vice versa.

Not quite. Revoke-all is about scope by subject, not channel: whether an opt-out from one type of informational message ends messages on unrelated matters. It is waived until January 31, 2027, and an order the FCC adopted on September 30, 2026 narrows it once that order takes effect.

4. Where does a revocation belong once it is captured?

Not quite. Revocations must outlive the campaign that produced them. A suppression that lives in a campaign export dies with the campaign.

Right. The moment a revocation is captured it goes on a durable list that outlives the campaign. When voice, SMS and email read three lists instead of one, there are three chances to fail.

Not quite. No external file tells you that someone asked you to stop. That record only exists inside your own operation, and no scrub can reconstruct it.

Where this sits relative to scrubbing

Worth being clear, because the categories get blurred: this is a your systems problem, not a data-vendor problem. No external file tells you that someone asked you to stop -- that record only exists inside your own operation, and no scrub can reconstruct it.

What external checks cover is the adjacent risk. A list can be perfectly suppressed and still full of disconnected numbers, landlines, and serial litigators who never opted out because being called is the point. Those are complementary problems. Solving one has never solved the other, and the 10-day rule does not change that -- it just shortens the time you have to get your half right.

For the full current position, see the TCPA compliance guide.

Frequently asked questions

What counts as a valid revocation?

Any reasonable method. The seven magic words -- stop, quit, revoke, opt out, cancel, unsubscribe, end -- are treated as automatically effective, but they are a floor rather than a list. An order the FCC adopted on September 30, 2026 (FCC 26-67) lets callers designate an exclusive opt-out method once it takes effect, and asks whether to shorten the 10-business-day window; neither change is in force.

A reply text in other words must be honoured if a reasonable person would read it as a revocation, and other routes, such as a voicemail or email, create a rebuttable presumption that consent was revoked. In practice that means a reply of "please stop calling me" counts, and so does telling an agent on a live call. Rebutting the presumption is your burden, not theirs.

Does an opt-out on one channel stop the others?

Yes, and this part is settled. Since April 11, 2025, a revocation made in any reasonable way covers both robocalls and robotexts from that caller, whichever channel it arrived on. What is unsettled is scope by subject: the "revoke-all" provision, which would make an opt-out from one type of informational message end messages on unrelated matters, is waived until January 31, 2027, and an order the Commission adopted on September 30, 2026 (FCC 26-67) narrows it to the category of informational robocall the opt-out answered, from 30 days after the order's Federal Register publication. See the FCC's TCPA opt-out order.

That open question is a poor foundation for a business decision. A consumer who texts STOP about one thing and then receives a marketing call about another has an obvious grievance whatever the waiver says, and the cost of suppressing across channels is close to zero. Suppress broadly.

Is 10 business days a target or a deadline?

A deadline, and an outer one. Nothing rewards you for using the full window. Every call placed between the revocation and the suppression is a call to someone who has already told you to stop -- technically inside the window, and exactly the fact pattern that produces a claim.

Do I still need an internal do-not-call list?

Yes, and it is separate from both the national registry and your consent records. A revocation has to persist after the campaign that produced it ends, which means it belongs in a durable suppression list rather than in a campaign export. See the Do Not Call Registry entry for how the obligations differ.

Not legal advice. NumberBroom is a phone data and list hygiene tool, not a law firm. This page summarises publicly available federal rules as of October 8, 2026 and is provided for general information only. TCPA and state telemarketing law change frequently and apply differently depending on your business, your consent records, and the states you call. Consult qualified counsel before relying on any of it.
Preview 20 rows of your list free
Drop a CSV and see line type, carrier and litigator status on the first 20 rows before you pay anything. Then $0.20 per number, less past 2,000 rows, $5 minimum, no subscription.
Preview 20 rows free

Founder, NumberBroom · 10 years in telecommunications and marketing

Cameron Hoffman is the founder of NumberBroom and has spent 10 years working in telecommunications and marketing. He built NumberBroom after repeatedly watching outbound teams dial purchased lists that were full of dead numbers, landlines and TCPA litigators.