TCPA consent revocation rules: what counts as an opt-out and how fast to honor it

What the FCC revocation rule says

A consumer can revoke consent to robocalls and robotexts by any reasonable method that clearly expresses a wish to stop. You must honor the request within a reasonable time, and never later than 10 business days from receipt. You may not name one exclusive way to opt out. The rule is 47 CFR 64.1200(a)(10).

The FCC adopted it in its Report and Order, FCC 24-24, on 02/15/2024 and released it on 02/16/2024 (CG Docket No. 02-278). The Commission published the effective date in the Federal Register on 10/11/2024. The main provisions took effect on 04/11/2025.

A "robocall" or "robotext" here means a call or text made with an autodialer, or a call with an artificial or prerecorded voice. The rule also covers telemarketing calls to a number on the National Do Not Call Registry made on the person's signed permission (47 CFR 64.1200(c)(2)). Other live, manually dialed calls fall under the do-not-call rules covered below.

Three methods are reasonable per se:

• An automated opt-out mechanism on a call.
• A reply text.
• A designated website or phone number.

Other wording counts if a reasonable person would understand it as a revocation. In a dispute the sender may try to show that the wording was not a reasonable revocation, and the FCC or a court weighs the totality of the circumstances. Honoring an unclear reply costs less than defending it.

The keywords and the confirmation text

A reply of any of seven words is a revocation: stop, quit, end, revoke, opt out, cancel or unsubscribe. As a house practice, match them regardless of capitalization or punctuation. You may send one confirmation text. It must only confirm the opt-out and carry no marketing content. If you send it within five minutes of receipt, the rule presumes it falls within the consent the person already gave. A slower confirmation needs a showing that the delay was reasonable.

Do not use the confirmation to ask the person to reconsider or to offer a different list. That turns a safe message into a marketing text sent without consent.

What is delayed to 01/31/2027

The "revoke-all" requirement says a revocation made in reply to one type of message applies to all future robocalls and robotexts from that caller on unrelated matters. The FCC delayed it twice.

• 04/07/2025: the FCC granted a waiver moving the date from 04/11/2025 to 04/11/2026. Bank trade groups had asked for it, citing the work of making every business unit stop at once.
• 10/29/2025: the FCC asked for comment on modifying the requirement (FCC 25-76).
• 01/06/2026: the Bureau issued DA 26-12 and moved the date to 01/31/2027, to review the record.

The rest of the revocation rule is in force now. The FCC may rewrite the delayed piece before 01/31/2027. Build suppression at the phone-number level across all your campaigns anyway. It is cheaper than splitting it later.

How revocation meets the do-not-call and email rules

A revocation of consent is separate from a do-not-call request, but one event can trigger both.

• Company-specific do-not-call list. The Telemarketing Sales Rule bars calling a person who has said they do not want calls from the seller (16 CFR 310.4(b)(1)(iii)(A)). The FCC rule at 47 CFR 64.1200(d) caps the time to honor such a request at 10 business days and requires honoring it for five years. Most live calls fall here.
• Safe harbor. The TSR shields a seller from liability for a call made in error only with written procedures, trained staff, a recorded do-not-call list, a registry version no more than 31 days old, and monitoring (16 CFR 310.4(b)(3)). See the National Do Not Call Registry page for the scrub rules.
• Email. CAN-SPAM requires you to honor an opt-out within 10 business days. The opt-out mechanism must work for at least 30 days after you send. You cannot charge a fee or ask for more than an email address. See CAN-SPAM and cold email.

Opt-out rules by channel

Channel	Opt-out method	Deadline	Cite
Marketing text (autodialed)	Any reasonable reply; STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, UNSUBSCRIBE always count	Reasonable time, max 10 business days	47 CFR 64.1200(a)(10)
Prerecorded or artificial voice call	Automated opt-out on the call, reply, or designated site or number	Reasonable time, max 10 business days	47 CFR 64.1200(a)(10)
Live telemarketing call	Verbal do-not-call request	Max 10 business days; honor 5 years	47 CFR 64.1200(d); 16 CFR 310.4(b)(1)(iii)(A)
Marketing email	Reply or link; no fee	10 business days; works 30 days after send	FTC CAN-SPAM guide
Confirmation text	One message, no marketing	Presumed fine within 5 minutes	47 CFR 64.1200(a)(12)

Links to the sources for each row are in the list at the end of this page. For the broader consent framework, read the TCPA explained.

The single policy that clears all of it

1. Accept any reasonable wording, not only the seven keywords. Route unclear replies to a person the same day.
2. Suppress the phone number at once on STOP. Treat the 10 business days as a legal ceiling, never a target.
3. Treat every revocation as global across your texts, calls and campaigns now, so the 01/31/2027 date changes nothing.
4. Send at most one plain confirmation text within five minutes. No offers.
5. Share one suppression table across channels. Add the email address and the phone number to it together when a person opts out of either.
6. Never offer one exclusive opt-out path. Keep the reply, the web form and the phone number all working.
7. Scrub every list against your suppression table before each send, including older aged leads you re-contact. Consent given years ago does not survive a later revocation.
8. Run the national registry scrub at least every 31 days.

The SMS text prospecting how-to and the 10DLC rules page show where these steps fit in a live program. Counts of reachable owners are on the homeowner counts page.

Record-keeping

Keep proof that you honored each request. The TSR sets a baseline of 5 years from the date a record is made (16 CFR 310.5(a)). For do-not-call requests, keep the person's name and numbers, the seller, the date of the request and the product (310.5(a)(10)). For consent, keep the name, number, a copy of the request as shown, the consent given and the date (310.5(a)(8)). For revocations, use the same five-year period as a house rule. Log the date and time received, the date and time suppressed, and the reply text.

Field	Why
Phone number and email	Match across channels
Received timestamp	Starts the 10 business day clock
Suppressed timestamp	Proves speed
Raw reply text	Shows what the person said
Source campaign	Finds the cause of complaints

Penalty exposure

A person can sue for $500 per violation or actual loss, whichever is greater. A court may raise the award to as much as three times for willful or knowing violations (47 U.S.C. 227(b)(3)). State attorneys general can sue over a pattern of violations for the same relief (227(g)). A CAN-SPAM violation carries penalties of up to $53,088 per email, according to the FTC guide. A text sent after a valid revocation is a separate violation, so a campaign that ignores a STOP file multiplies the exposure. See telemarketing penalties for case-level numbers.

What changed in the last 24 months

• 10/11/2024: effective date for FCC 24-24 rules published, set for 04/11/2025.
• 04/07/2025: revoke-all piece waived to 04/11/2026.
• 04/11/2025: revocation by reasonable means, keywords, confirmation text and the 10 business day limit took effect.
• 10/29/2025: FCC sought comment on changing revoke-all.
• 01/06/2026: DA 26-12 moved revoke-all to 01/31/2027.
• Separately, on 01/24/2025 the Eleventh Circuit vacated the FCC's one-to-one consent rule before it took effect, so consent may still cover more than one seller, and each of those sellers must honor a revocation (Insurance Marketing Coalition v. FCC, No. 24-10277).

Next step

Check the size of the audience you plan to message before you build suppression logic around it. Request counts at /get-counts/. The hub for related rules is /compliance/.

This page is a plain-English summary with sources, not legal advice. Last reviewed 10/10/2026.

Questions people ask

Q01Can I make people reply only with STOP?

No. The rule bars a sender from designating an exclusive means of revoking. STOP must work, and so must any other reasonable wording, such as 'please don't text me again', if a reasonable person would read it as a revocation.

Q02Do I have to wait 10 business days to stop texting?

No. Ten business days is the outer limit, not a grace period. The rule says a reasonable time not to exceed 10 business days. A STOP reply to an automated text should suppress the number almost at once.

Q03What if my texting platform cannot receive replies?

Then each text must say clearly that two-way texting is not available because of the protocol, and must list reasonable other ways to revoke, such as a phone number or web link. Without that disclosure, a no-reply sender has no compliant opt-out path under 47 CFR 64.1200(a)(10).

Q04Does an email unsubscribe also stop my texts?

Not by rule. CAN-SPAM governs email and the TCPA governs calls and texts. Honoring only one channel is lawful, but a person who unsubscribes by email and is then texted often complains. Sharing suppression across channels removes the risk.

Q05Is a confirmation text a violation?

No, if it is sent once, only confirms the opt-out, and has no marketing content. A confirmation sent within five minutes of the request is presumed to fall within the consent the person already gave.

Sources

1. FCC 24-24, Report and Order and Further Notice (adopted 02/15/2024, released 02/16/2024)docs.fcc.gov
2. FCC DA 26-12, Order extending the revoke-all waiver (01/06/2026)docs.fcc.gov
3. 47 CFR 64.1200, Delivery restrictions (Cornell LII mirror of the CFR)law.cornell.edu
4. 16 CFR 310.4, Abusive telemarketing acts or practiceslaw.cornell.edu
5. 16 CFR 310.5, Recordkeeping requirementslaw.cornell.edu
6. 47 U.S.C. 227, Telephone Consumer Protection Actlaw.cornell.edu
7. FTC, CAN-SPAM Act: A Compliance Guide for Businessftc.gov
8. Insurance Marketing Coalition v. FCC, No. 24-10277 (11th Cir. 01/24/2025)media.ca11.uscourts.gov
9. Burr & Forman summary of the revoke-all delay (secondary)burr.com