November 2, 2026

On September 30, 2026, the Federal Communications Commission (FCC) adopted a Report and Order and Further Notice of Proposed Rulemaking (FCC 26-67) in CG Docket No. 02-278 that significantly revises how callers and texters must handle consumer requests to revoke consent under the Telephone Consumer Protection Act (TCPA).

Key Takeaways

• Narrower “revoke all.” Callers may treat an opt-out made in response to an informational robocall or robotext as applying only to that category of informational communications, not to all communications from the caller.

• Exclusive revocation methods. Callers may designate one or more of three automated methods as the exclusive means to revoke consent, if the method is clearly and conspicuously disclosed on each call or text.

• New text-disclosure accommodation. Texters relying on reply-text opt-outs can satisfy the disclosure requirement by including one standardized opt-out word (e.g., “stop”) in each message, but must honor all seven standardized words.

• Fraud alert exemption expanded. Financial institutions may send exempt fraud and data-security alerts to wireless numbers obtained from specified “reliable sources,” not only numbers the customer provided.

• Short runway. The amendments take effect November 25, 2026, superseding the January 31, 2027 waiver date for the “revoke all” provision. The FCC rejected a request for a 12-month implementation period.

• Further changes proposed. The FCC seeks comment on shortening the 10-business-day honoring deadline, mandating two-way texting, requiring a “revoke all” option, affiliate treatment, and confirmation messages. Comments are due November 25, 2026; replies are due December 28, 2026.

Background

The 2024 TCPA Consent Order adopted 47 C.F.R. § 64.1200(a)(10), which bars a caller from sending further robocalls or robotexts once a called party revokes consent by any reasonable method. The rule was read to require callers to apply an opt-out made in response to one type of message to all future robocalls and robotexts from that caller, even on unrelated matters. The FCC’s Consumer and Governmental Affairs Bureau (CGB) delayed the effective date of that “revoke all” requirement, first to April 11, 2026, and then to January 31, 2027, to allow the FCC to review the record in its 2025 rulemaking and avoid potentially unnecessary compliance costs. The new Order resolves that rulemaking.

What the Report and Order Does

1. Category-Specific Revocation for Informational Communications

Callers may now treat a revocation request made in response to an informational call or text (one with no advertising or telemarketing) as applying only to the category of informational robocalls and texts to which it was directed. The FCC found the existing “revoke all” approach overinclusive—an opt-out from payment reminders, for example, would otherwise cut off fraud alerts, multi-factor authentication codes, appointment reminders, or utility outage notices—and often inconsistent with consumer intent.

Marketing is different. An opt-out made in response to a call or text that contains an advertisement or constitutes telemarketing revokes consent to all future advertising and telemarketing robocalls and texts from that caller. The FCC also reminded telemarketers that do-not-call requests extend to affiliates when the consumer would reasonably expect them to be included.

2. Exclusive Revocation Methods

Callers may designate one or more of the following as the exclusive means to revoke consent:

• an automated, interactive voice or key-press-activated opt-out mechanism on a call;

• a reply text using any one of the standardized words “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe”; and/or

• a website or telephone number designated by the caller to process opt-out requests.

Callers must clearly and conspicuously disclose the designated method on the call or in the text; the FCC declined to let callers decide when and how to make that disclosure. A caller that designates an exclusive method need not process revocations made by other means. Callers that do not designate one must continue to honor revocations made by any reasonable means, subject to the relevant rebuttable-presumption and totality-of-the-circumstances framework.

One-word disclosure for texts. The Order clarifies that a texter designating reply text as its exclusive method satisfies the disclosure obligation by including at least one standardized word in each message (e.g., “Reply STOP to opt out”), provided it accepts any of the seven standardized words as a valid revocation. This avoids lengthy disclosures given text-message character limits.

Under either path, callers must honor revocations within a reasonable time not to exceed ten business days. Texters using one-way protocols must still disclose in each text that reply texts are unavailable and provide a reasonable alternative opt-out method.

3. Expanded Fraud Alert Exemption for Financial Institutions

The FCC amended § 64.1200(a)(9)(iii)(A) so that financial institutions may send exempt alerts (concerning transactions suggesting fraud or identity theft, data-security breaches, remedial steps, and pending money transfers) to wireless numbers that the customer provided or that were obtained from a reliable source. A reliable source is a number (i) supplied by a spouse or other family member authorized on the account, (ii) obtained when the customer calls the institution, or (iii) included in records obtained from another financial institution. The exemption’s other conditions remain, including the limit of three messages per event over three days and the obligation to honor opt-outs immediately. The FCC declined to extend the exemption to other message types or non-financial businesses.

Effective Date

The FCC published the Order in the Federal Register on October 26, 2026, and the amendments take effect November 25, 2026. The modified § 64.1200(a)(10) takes effect on that date and supersedes the delayed January 31, 2027 effective date for the “revoke all” provision.

Further Notice of Proposed Rulemaking (FNPRM)

In the FNPRM, the FCC seeks comment on:

• Honoring timeframe: whether to reduce the ten-business-day deadline (e.g., to seven business days) and whether the deadline should differ for callers that designate exclusive methods;

• Two-way texting: whether to eliminate the one-way texting option or to require two-way texting only for marketing messages;

• “Revoke all” option: whether category-specific revocation should be conditioned on offering a one-step, possibly automated, method to revoke consent to all messages, and whether revocations should apply only to the specific number revoked rather than to all numbers on an account;

• Affiliates and lines of business: whether to modify the affiliate standard in § 64.1200(d)(5) or extend it to all robocalls;

• Other issues: other industry proposals, including reducing the list of standardized words, eliminating the rebuttable presumption, permitting confirmation calls or texts, and allowing texters to ask consumers to clarify which message category they intended to opt out of.

Comments are due on or before November 25, 2026, and reply comments are due on or before December 28, 2026.

What Businesses Should Do Now

• Map informational message programs into defined categories and update opt-out processing to apply revocations to the correct category, while continuing to apply marketing opt-outs to all marketing.

• Decide whether to designate exclusive revocation methods and, if so, update call scripts and text templates to include clear and conspicuous disclosures (at least one standardized word for texts).

• Confirm that systems recognize all seven standardized words and process revocations within ten business days.

• Financial institutions should review number-sourcing practices against the new “reliable source” categories and continue to observe the exemption’s volume and opt-out conditions.

• Complete implementation before the November 25, 2026 effective date.

• Consider filing comments on the FNPRM by November 25, 2026 (replies by December 28, 2026).

This alert is for informational purposes only and does not constitute legal advice.