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 answerWithin 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.
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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.
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.
- FCC -- CGB extends the effective date of the TCPA's consent revocation rule (DA 26-12, January 6, 2026)
- FCC -- Report and Order and FNPRM on consent revocation, adopted September 30, 2026 (FCC 26-67)
- 47 U.S.C. § 227 -- Restrictions on the use of telephone equipment (Cornell LII)
- 47 C.F.R. § 64.1200 -- Delivery restrictions (Cornell LII)