A company that texts customers in Spanish should expect a Spanish reply like ALTO or BASTA to be treated as a valid opt-out. The FCC’s revocation rule names seven English words as automatic revocations and requires a sender to honor other words a reasonable person would read as a request to stop. The FCC’s 2024 order adds that a reply in the campaign’s language can meet that test. Bilingual programs with English-only keyword filters carry exposure their platform reports won’t show.
What does the FCC’s revocation rule say about other languages?
The rule itself doesn’t mention language. It sets a reasonableness test that does the same work. Under 47 C.F.R. § 64.1200(a)(10), if a reply uses words other than the listed ones, “the caller must treat that reply text as a valid revocation request if a reasonable person would understand those words to have conveyed a request to revoke consent.”
The FCC spoke to language directly in the order that adopted the rule. In a footnote to the 2024 Report and Order, FCC 24-24, the Commission wrote: “Where a texter sends a consumer messages in a language other than English at the consumer’s request and the consumer attempts revocation in that language using its equivalent of these words, the finder of fact may conclude the revocation attempt is reasonable under a totality of the circumstances analysis.”
Commissioner Gomez’s separate statement on the same order put it more bluntly. Her statement says “If you get a message in Spanish, you can respond in Spanish to opt-out.” A commissioner’s statement isn’t the Commission’s ruling, but plaintiffs’ lawyers will quote it, and the footnote gives them the same point in the order’s own text.
Is a Spanish reply a per se revocation like STOP?
Not under the text of the rule, though the difference may not help much in court. The per se list in § 64.1200(a)(10) is seven English words, and the rule treats a reply using one of them as “a reasonable means per se to revoke consent.” A reply in Spanish goes through the reasonable-person test instead.
That test favors the consumer when the campaign itself was in Spanish. A company that chose to market in Spanish will have trouble arguing that a reasonable person wouldn’t understand ALTO or NO MÁS MENSAJES as a request to stop. The footnote says the finder of fact may reach that conclusion, which leaves the question to the finder of fact. That’s a real argument in a case with unusual facts, such as a one-word reply in a third language to an English campaign. It’s a weak argument when the company’s own texts were in the same language as the reply.
There’s also the post-2025 question. After McLaughlin Chiropractic Associates v. McKesson Corp. (2025), district courts in private suits read the TCPA for themselves. The revocation rule’s text, which was adopted through notice-and-comment rulemaking, carries more weight than an interpretive footnote. A defendant can argue that the footnote isn’t binding, but the rule’s own reasonable-person standard reaches most of the same replies without it.
Which campaigns carry the most risk?
The ones where the language of the messages and the language of the opt-out processing don’t match. A program can send Spanish templates for months while the platform’s keyword list recognizes only English words, because nobody on the marketing team thought to ask the vendor how replies in other languages get processed. Every Spanish reply that isn’t one of the listed English words then lands in an inbox, or nowhere, and the texts keep going.
| Situation | How a court is likely to treat a Spanish reply | What answers the claim |
|---|---|---|
| Campaign sent in Spanish, reply ALTO or BASTA | Likely a reasonable revocation | Proof the number was suppressed within the rule’s time limit |
| Bilingual campaign, reply in Spanish | Likely a reasonable revocation | Keyword lists covering both languages, and suppression records |
| English campaign, reply in Spanish | Disputed, and the facts decide it | Evidence of what the sender could reasonably have understood |
| Reply in Spanish, sender answers with one confirmation text | Covered by § 64.1200(a)(12) if it only confirms the opt-out | The timestamp and text of the confirmation message |
| Reply in Spanish, texts continue for weeks | Exposure for each later text | Consent scope and individual defenses, which are thin |
The deadline for honoring a revocation creates its own exposure, and plaintiffs often plead it alongside the keyword problem. The rule requires that revocation requests “must be honored within a reasonable time not to exceed ten business days from receipt of such request.” A company that catches Spanish opt-outs through a weekly manual review of the inbox may be inside that window or outside it, depending on the week.
Damages for texts sent after a revocation run up to $500 per text under 47 U.S.C. § 227(b)(3), and a court may increase that to up to three times the amount if it finds the violation was willful or knowing. A reply the company’s own staff read and didn’t act on is the fact pattern plaintiffs use to argue the later texts were knowing.
Does consent collected in English cover a Spanish campaign?
Usually, if the consent itself was valid. The language of the later texts doesn’t change who agreed to receive them. The harder question runs the other way: consent language a Spanish-speaking customer couldn’t read.
For marketing texts sent with an autodialer or an artificial or prerecorded voice, the FCC’s rules require prior express written consent with a “clear and conspicuous” disclosure. The rule at § 64.1200(f)(3) defines that term as “a notice that would be apparent to the reasonable consumer.” A company that runs Spanish-language ads leading to an English-only consent page has handed the plaintiff an argument that the disclosure wasn’t apparent to the consumer it targeted. After Facebook v. Duguid, most texting platforms aren’t autodialers, so that argument often matters more under state laws with broader definitions than under the federal rule.
The practical fix is cheap, and it’s one that marketing teams running Spanish-language ads can usually put in place within a week without changing anything else about the campaign. A consent page served in the language of the ad that sent the consumer there, with the archived version kept, closes the argument before it starts. The earlier post on TCPA consent scope covers the related problem of consent that doesn’t reach the kind of message sent.
What to pull when a Spanish opt-out claim arrives
- Put a litigation hold on the platform’s send and reply logs for the claimant’s number, along with the consent record and the archived consent page in each language the program used.
- Export the opt-out and suppression history for the number, with the date each reply arrived and the date suppression took effect.
- Pull the National Do Not Call Registry scrub records for the campaign and the Registry version dates.
- Collect the vendor contract, the platform’s keyword configuration for each language, and the message templates in every language sent.
- Have a lawyer review the file before responding to the demand or offering money to the claimant.
Keyword configuration is the record most companies can’t produce. Platforms let administrators add opt-out keywords whenever they like, and the history of who changed the list and when is often overwritten or never kept at all, which leaves the company guessing about its own settings. Lawyers who defend TCPA claims will ask for a screenshot or export of the keyword list as it stood during the campaign, so saving one whenever the list changes is worth the minute it takes.
Questions about Spanish-language opt-outs
Which Spanish words should a keyword list include?
The rule doesn’t publish a Spanish list, so a company has to choose its own. Common choices start with ALTO and BASTA and extend to phrases like NO MÁS, entered both with and without accents, since many phones drop them. A list that’s broader than necessary costs little. Missing one common word can cost a text per message sent after it.
Can we require customers to opt out by replying STOP in English?
No. The rule provides that senders “may not designate an exclusive means to request revocation of consent.” A disclosure telling customers to reply STOP is fine as an instruction, but it doesn’t make a Spanish reply ineffective. The reasonable-person test still applies to whatever the customer actually sends.
Does the same reasoning apply to other languages?
The footnote in FCC 24-24 isn’t limited to Spanish. It covers any language the texter used at the consumer’s request. Campaigns in Vietnamese or Tagalog are common in California, and each language needs its own opt-out words. A company that markets in a language should be able to read replies in it.
What about voice calls in Spanish?
The revocation rule covers calls as well as texts. A customer who asks an agent, in Spanish, to stop calling has made a request a reasonable person would understand. For telemarketing calls, the request also has to go on the internal do-not-call list under the rules covered in the earlier post on internal do-not-call policies.
Defending claims over non-English text campaigns
If your company is accused of texting a customer after a reply in Spanish or another language, the keyword configuration and the suppression dates usually decide the case. Rosenberger + Kawabata represents businesses defending TCPA lawsuits and class actions through its business litigation practice, including claims involving texts sent after a non-English opt-out reply. Contact Rosenberger + Kawabata online for a confidential consultation, or call (310) 894-6921.
Sources
The statute is the Telephone Consumer Protection Act, 47 U.S.C. § 227. The FCC’s rules are at 47 C.F.R. § 64.1200, as published in the eCFR on July 1, 2026. The order that adopted the revocation rule is the FCC’s Report and Order in CG Docket No. 02-278, FCC 24-24 (released Feb. 16, 2024).
This post is general information about the Telephone Consumer Protection Act and related laws as of July 11, 2026. It is not legal advice, and reading it does not create an attorney-client relationship. Courts and the FCC change the rules in this area often, and the outcome of any claim depends on its facts. Past results do not guarantee future outcomes.