On September 30, 2026, the FCC adopted an order letting businesses that robocall or robotext designate a single, exclusive opt-out method, as long as every call or text discloses it. The rules take effect November 25, 2026. The order also lets companies treat an opt-out from an informational message as limited to that category, and it replaces the broader “revoke all” rule before that rule ever took effect. For most companies that text customers, adopting and disclosing an exclusive method is the most useful compliance step this year.
What the FCC adopted
The order is FCC 26-67, adopted September 30 and released October 1, 2026. It rewrites the consent-revocation rule at 47 C.F.R. § 64.1200(a)(10).
Exclusive opt-out methods. Under the new rule text, “Callers may designate any of the following methods as the exclusive means to revoke consent”: an automated key-press or voice opt-out on a call, a reply using one of seven standard words, or a website or phone number set up for opt-outs. The condition is disclosure, according to the order: “The caller must clearly and conspicuously disclose the designated method to revoke consent on the call or in the text.” Text senders can satisfy it by including one standard word, such as STOP, in each message.
Category-specific opt-outs for informational messages. A company may read an opt-out from an informational call or text “as applying only to the specific category of informational robocalls and text messages to which the revocation was directed and not to all communications,” according to the order. Marketing works the other way: opt-outs from marketing “revoke consent to all future calls or text messages containing an advertisement or constitute telemarketing from that caller.”
Fraud alerts. Banks may send exempt fraud-alert messages to wireless numbers obtained from what the order calls a reliable source, such as an authorized family member on the account, not only numbers the customer provided.
Effective date. “The revised rule amendments contained herein become effective 30 days after Federal Register publication,” per FCC 26-67. The order appeared in the Federal Register on October 26, 2026, at 91 Fed. Reg. 67214, and the published rule states: “Effective November 25, 2026.” Until that date, the current revocation rule described below still governs.
The rule it replaces
Today’s rule, in the current eCFR text of § 64.1200, lets consumers revoke consent by any reasonable method. A reply in other words still counts: the sender “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.” Companies have a reasonable time, and no more than ten business days, to honor it.
The 2024 version would have made an opt-out from one type of message stop all robocalls and robotexts from that sender. The FCC’s consumer bureau delayed that piece repeatedly, most recently until January 31, 2027, and the new order says it will “supersede the delayed effective date of the relevant portion of that rule that was previously extended to January 31, 2027.” The broad version never took effect. Our 2025 year-in-review post covers that delay and the FCC’s October 2025 proposal.
What businesses should change
Designate and disclose an exclusive method. A company that does this “is not required to process revocation requests made by any other means,” under the new rule text, though “text senders still must honor revocation requests made using any of the standardized words,” the order says. Companies that don’t designate one keep the old standard: they “must process revocation requests made by any reasonable means.”
I’d make that designation in every texting program. Free-form opt-outs are where litigation lives today: a customer asks in their own words to be taken off the list, the system doesn’t recognize it, and three more texts go out. Once the order is effective, a STOP instruction disclosed in every message narrows that risk considerably.
Separate informational and marketing streams. The category-specific rule only helps if the company’s systems can tell a payment reminder from a promotion and suppress them separately. Companies that send both from one short code should look at splitting them.
Keep the ten-business-day clock. Both the old and new text require honoring revocations within ten business days. The order’s further notice asks whether to shorten that.
What the order leaves alone
Do Not Call obligations don’t change. Telemarketers still keep internal do-not-call lists, honor requests within ten business days, and scrub against the National Do Not Call Registry under § 64.1200.
The order also doesn’t settle litigation questions. After McLaughlin Chiropractic Associates v. McKesson Corp., courts read the TCPA for themselves, and FCC consent rules can be challenged: the Eleventh Circuit vacated the FCC’s one-seller-at-a-time consent rule in Insurance Marketing Coalition v. FCC. Compliance with the new rule is still the best evidence a company can offer that it respected an opt-out. Our post on McLaughlin v. McKesson covers how courts now treat FCC rulings.
More changes may come. The order seeks comment on “updating various TCPA rules relating to the timeframe callers must honor revocation requests, requirements for two-way texting functionality, requiring a revoke all method, and the treatment of affiliates,” according to FCC 26-67. One proposal would cut the ten-business-day deadline to seven.
Getting ready for November 25
- Preserve current opt-out logs and message templates now, so the company can show how revocations were handled before and after the change.
- Audit the opt-out pipeline: which replies are recognized, how unrecognized replies are routed, and how long suppression takes.
- Confirm that marketing suppression also feeds the internal do-not-call list and the Registry scrub process.
- Update message templates and call scripts to disclose the designated opt-out method, and collect vendor agreements that control how those messages are sent.
- Talk to a lawyer before changing consent language or opt-out handling for an active campaign that’s already the subject of a complaint.
The firm’s page on TCPA litigation defense explains how claims involving consent revocation and opt-out processing move from a demand letter to a lawsuit.
Getting ahead of the new opt-out rules
If your company sends robocalls or robotexts, the FCC’s new order changes how opt-outs have to be disclosed and processed, and claims over ignored opt-outs are already common. Rosenberger + Kawabata represents businesses defending TCPA lawsuits and class actions through its business litigation practice, including claims involving consent revocation and opt-out processing. Contact Rosenberger + Kawabata online for a free and confidential consultation, or call (310) 894-6921.
Sources
The FCC’s order is FCC 26-67, Report and Order and Further Notice of Proposed Rulemaking, CG Docket No. 02-278 (adopted Sept. 30, 2026, released Oct. 1, 2026), published as Enhancing the Ability of Consumers To Control the Robocalls, 91 Fed. Reg. 67214 (Oct. 26, 2026) (effective Nov. 25, 2026). The current rule is 47 C.F.R. § 64.1200, as published in the eCFR through October 23, 2026. The court decisions are McLaughlin Chiropractic Associates v. McKesson Corp., 606 U.S. 146 (2025), and Insurance Marketing Coalition Ltd. v. FCC, No. 24-10277 (11th Cir. Jan. 24, 2025).
Updated October 27, 2026, to add the order’s Federal Register publication and its November 25, 2026 effective date.
This post is general information about the Telephone Consumer Protection Act and related laws as of October 27, 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.