On October 1, 2026, the FCC released a new Report and Order that amends its rules implementing the Telephone Consumer Protection Act (TCPA), including 47 C.F.R. § 64.1200. The changes address how consumers may withdraw consent to receive certain automated calls and texts (which the FCC calls “robocalls” and “robotexts”).
Most notably, the FCC moved away from its broad “Revoke-All” Rule and now allows callers more control over the methods consumers may use to opt out. The amendments will take effect 30 days after the Order is published in the Federal Register.
This article explains what changed and why businesses should carefully design—and clearly disclose—their opt-out processes.
What Changed?
Several changes to the FCC’s TCPA rules were originally set to take effect on April 11, 2025. One of them—the Revoke-All Rule—would have treated a consumer’s opt-out from one type of robocall as an opt-out from every robocall and robotext from that caller, even if the messages covered unrelated topics. The FCC delayed that rule for one year because of concerns about its breadth. In January 2026, the FCC delayed it again, until January 31, 2027, while considering revisions.
The FCC’s October 1, 2026 Report and Order revises the Revoke-All Rule in three main areas:
- The scope of opt-out requests made in response to informational and sales robocalls and robotexts.
- Caller’s ability to designate one exclusive opt-out method.
- Confirmation texts sent after an opt-out request.
How Much Does an Opt-Out Cover?
Both the original and revised Revoke-All Rules address Section 227(b) of the TCPA. That section regulates calls and texts made with an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice. (In practice, text messages generally do not contain a voice.)
Unless an emergency or another exemption applies, a caller generally needs the called party’s prior express consent. If that type of call or message includes an advertisement or is telemarketing, the caller needs prior express written consent.
Informational Messages
Under the revised rule, an opt-out request made in response to an informational robocall or robotext applies only to the category of informational messages at issue—not to every communication from that caller.
The FCC explained that this approach lets consumers stop categories they do not want, while continuing to receive useful messages. Examples include fraud alerts, multifactor-authentication messages, appointment reminders, and utility-outage notices.
Sales Messages
A different rule applies when a consumer opts out in response to a sales robocall or robotext—that is, a communication that includes an advertisement or constitutes telemarketing and therefore requires prior express written consent. In that situation, the request applies to all future sales calls and texts from that caller.
Because the scope of an opt-out depends on whether a message is informational or sales-related, callers must accurately classify each category of calls and texts. (As a rule of thumb, if a call or message has both informational and marketing content, treat it as a marketing call or text.)
Callers May Choose One Exclusive Opt-Out Method
Under the revised rule, a caller may select one of three options as the only method consumers may use to opt out. The earlier version of the rule would not have allowed callers to limit consumers to one designated method.
The three options are:
- Provide an automated, interactive voice or keypress opt-out mechanism during a call;
- Require a text recipient to reply with one of these terms: “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe”; or
- Designate a website or telephone number for processing opt-out requests.
If a caller designates one option as its exclusive opt-out method, it generally does not have to process requests submitted another way. (We should not assume, however, that the CTIA and wireless carriers are going to abandon their stop-processing requirements.)
The caller must, however, clearly disclose the designated method in its calls and texts. If it requires consumers to opt out by reply text, the disclosure must identify at least one of the seven permitted terms. Even then, the caller must honor a reply that uses any of the seven terms listed in the rule.
Designating an exclusive method can simplify compliance. A caller that does not designate one must process opt-out requests made by any “reasonable means,” which may require a case-by-case judgment about whether the consumer’s method was reasonable.
Regardless of the method used, callers must honor a valid opt-out request within a reasonable time—and no later than 10 business days after receiving it.
Confirmation Texts May Confirm, but Not Seek Clarification
The prior rule allowed a caller to send one text, within five minutes after receiving an opt-out request, to confirm receipt. If the consumer had agreed to receive several categories of texts, the caller could use that confirmation message to ask which categories the consumer intended to stop.
The revised rule still permits the one-time confirmation text, but the caller may no longer use it to seek clarification about the scope of the request.
What This Means for Outbound Teams
- Map message categories: Identify which robocalls and robotexts are informational and which include advertising or telemarketing. This classification determines how broadly an opt-out request applies.
- Choose and disclose an exclusive opt-out method: Using one of the permitted methods can reduce uncertainty about whether requests submitted through other channels must be honored.
- Act promptly: Honor valid opt-out requests as soon as reasonably possible. The 10-business-day period is an outside limit; meeting it does not automatically establish that the caller acted within a reasonable time.
The Takeaway
The FCC’s October 1 Report and Order gives callers two important forms of flexibility: informational opt-outs may be limited by message category, and callers may establish an exclusive opt-out method. Businesses should consider using that flexibility, but they must remember that an opt-out from sales robocalls or robotexts still covers all future sales calls and texts from that caller.
We will update this article with the amendments’ effective date after the Report and Order is published in the Federal Register.
This article is only offered for informational purposes; it is not legal advice. Please consult a qualified attorney for your specific compliance needs.
Joe Bowser
Joe Bowser is a partner at Roth Jackson. He has been practicing communications and marketing law for two decades. He advises and defends calling and SMS platform providers (like Readymode), carriers/VoIP providers, and heavy users of those services in their wide range of compliance needs. In his spare time, you can find him taking his boys to their sports, getting in a workout of his own, or catching an Arsenal match.
