New TCPA Opt-Out Rules: What to Change by Nov 25, 2026

The new TCPA opt-out rules take effect on November 25, 2026. You can now name one exclusive way to opt out, such as replying STOP. You still have at most 10 business days to honor every opt-out.

A STOP sent to a reminder can now end just that type of reminder. If you send reminders, payment nudges, review requests or AI follow-up texts, your opt-out logic was probably built for the old rules. Those rules made you honor an opt-out sent "by any reasonable means," including email, voicemail or a form note.

For the bigger picture, read our federal calling and texting compliance overview. This is general information, not legal advice, so have your attorney review your final setup.

Which texts and calls the new opt-out rules cover

If your reminders go out automatically from a scheduling app, a CRM or an AI voice agent, assume they count. The Telephone Consumer Protection Act (TCPA) covers what the FCC calls robocalls. In the new order, that means any autodialed text and any call using an artificial or prerecorded voice.

The order does three things a small business will feel:

• It lets you pick the door. You can designate an exclusive opt-out method. If you do, you no longer have to process opt-outs that arrive another way, like a reply to an old email.
• It splits informational and marketing messages. An informational message has no advertising in it, like an appointment reminder or a fraud alert. An opt-out sent in reply to one can be treated as ending only that kind of message.
• It kills the "revoke all" rule before it ever started. Under the 2024 rules, one STOP would have ended every consent-based message from you. That part had been delayed to January 31, 2027. The new order replaces it.

What one missed opt-out can cost

The law lets a person sue for $500 per violation. A court can raise that to three times the amount if the violation was willful or knowing. That is according to the TCPA statute at 47 U.S.C. 227.

A text sent after someone opted out is the kind of mistake that adds up one message at a time.

Eight changes to make before November 25

Most setups need eight fixes, from a message inventory to a dated test log. See the full FCC 26-67 order if you want the exact rule text. The rule language is in Appendix A.

1. List every automated message you send

Write down each message stream: who gets it, what triggers it, which tool sends it and whether it has an offer.

• Example: "Appointment reminder, 24 hours before, sent by the booking app, no offer." "Monthly promo, sent by the CRM, includes a discount."
• Quick check: Every stream has a label of informational or marketing. If a reminder also says "book a cleaning and save 10%," it is marketing.

2. Choose your exclusive opt-out method

Pick one or more of the three methods the FCC allows. Reply STOP on texts and a key press opt-out on automated calls are the easiest to automate.

• Example: Texts use reply keywords. AI voice calls offer "press 9 or say stop calling."
• Quick check: You can name the method for each message stream in one sentence.

3. Rewrite your templates to disclose it

The FCC requires the method to be "clearly and conspicuously" disclosed on the call or in the text. For texts, naming just one standard word is enough, as long as you honor all seven.

• Example: "Hi Dana, reminder: cleaning tomorrow at 2:00 PM. Reply C to confirm. Reply STOP to end appointment reminders."
• Quick check: Every template, including the ones your AI writes, ends with the opt-out line.

Here is how the main rules changed.

Source: FCC 26-67, Report and Order, adopted September 30, 2026, and the BHFS and Troutman Pepper Locke client alerts on the effective date.

Fix your follow-up automation

4. Make your system catch all seven words

Your inbound text handler must treat stop, quit, end, revoke, opt out, cancel and unsubscribe as opt-outs. That holds in any capital letters and with stray punctuation.

• Example: "Cancel." "STOP!!" "opt out please" all trigger an opt-out, not a reply from your AI chatbot.
• Quick check: Send each word from a test phone and confirm the contact is flagged. Most tools do this with a webhook that updates the CRM.

5. Store opt-outs by category in your CRM

The category rule only helps you if your CRM can store more than one yes or no. Add a field for each message category and one for marketing.

• Example: Dana texts STOP to a payment reminder. Payment reminders: off. Appointment reminders: on. Marketing: unchanged.
• Quick check: Pull one contact and see three separate consent fields, each with a date and the message that triggered it.

6. Send a confirmation text fast, and keep it plain

The rules allow one text that confirms the opt-out, with no marketing in it. If you send it within five minutes, it is presumed to be within the person's consent. Later than that, you may have to show the delay was reasonable.

• Example: "You will no longer get payment reminders from us. Appointment reminders continue. Reply STOP ALL to end everything."
• Quick check: Time it on a test phone. If it takes longer than a minute or two, find out why.

7. Handle calls and one-way texts

Some texts go out from a number that cannot receive replies. Then every text must say that replies are not available and give another way to opt out. For automated calls, Kelley Drye notes one more rule. Artificial or prerecorded voice calls, including AI-generated ones, must still offer an automated voice or key press opt-out.

• Example: Your AI voice agent says "To stop these calls, press 9 or say stop" near the start of the call.
• Quick check: Call your own line and opt out. Confirm the CRM updates without anyone touching it.

8. Test, log and set a review date

Run every path end to end and keep a dated record of each test. The FCC is still taking comments on shorter deadlines and two-way texting. Put a reminder on your calendar to recheck in early 2027.

• Example: A one-page test log with the date, the phone used, the word sent and the result.
• Quick check: You can show anyone, in under five minutes, how a STOP becomes a blocked send.

What a STOP does to each message type

A STOP on an informational text ends that category, while a STOP on a marketing text ends all marketing. Use this table to map each stream from Step 1.

Source: FCC 26-67, rule text in Appendix A. Category labels are our reading, not legal advice.

Related: Write the SOP First: Why Every AI Automation Starts With a Written Process

The exposure math for a dental office sending 2,000 texts a month

Example: here, 20 texts sent after an opt-out mean $10,000 of possible exposure in one month. These numbers are illustrative, not a real customer.

The office sends about 2,000 automated texts a month. That is 1,500 appointment reminders, 300 payment reminders and 200 promo texts. Assume 1% of recipients reply with an opt-out word, so about 20 people a month.

Under the old setup, the texting tool caught only "stop." Say 5 of those 20 people wrote "cancel" or "unsubscribe" instead. The tool missed them, and each kept getting about 4 more texts that month.

That is 5 people times 4 texts, or 20 texts sent after an opt-out. At the statute's $500 minimum per violation, that is $10,000 of possible exposure in a single month. If a court found it willful, the amount could be up to three times higher.

After the fix, all seven words trigger an opt-out, and each one goes into the right category field. A confirmation goes out within a minute. The 15 people who replied STOP to a payment reminder still get appointment reminders. The office keeps the reminders that prevent no-shows.

A 30-day schedule that finishes before the deadline

Spread the work over 30 days and you finish with an attorney review and a 2027 recheck date.

• ☐ Days 1 to 3: list every automated stream and label it informational or marketing.
• ☐ Days 4 to 6: choose your exclusive opt-out method for texts and for calls.
• ☐ Days 7 to 10: rewrite every template and AI prompt to disclose the method.
• ☐ Days 11 to 15: add category consent fields to your CRM and connect your texting tool.
• ☐ Days 16 to 18: set up the confirmation text and check it sends within five minutes.
• ☐ Days 19 to 22: test all seven words and the call opt-out from a real phone, and log results.
• ☐ Days 23 to 26: merge duplicate contacts so no opt-out is missed on a second record.
• ☐ Days 27 to 30: get an attorney review and book an early 2027 recheck.

If Dana is in your CRM twice, an opt-out on one record does nothing for the other. Our free CRM lead deduplicator merges duplicates before you rely on consent fields.

Common mistakes

• Only catching "stop." The rule lists seven words, and you must honor all of them even if you only mention one.
• Letting the AI chatbot answer an opt-out. If someone texts "cancel," your bot should not reply with a friendly question. It should process the opt-out.
• Mixing offers into reminders. One discount line turns an informational reminder into marketing. Then a STOP ends all of your marketing.
• Storing consent as one checkbox. One field cannot hold the category rule, so you lose the main benefit of the change.
• Forgetting other tools. Your booking app, CRM and voice agent may each send messages. Every one must read the same opt-out list.
• Assuming state law matches. Some states have their own calling and texting rules that can be stricter than federal rules.

FAQ

When do the new TCPA opt-out rules take effect?

They take effect November 25, 2026. The FCC adopted the order on September 30, 2026, and released it October 1. It was published in the Federal Register on October 26.

Do I have to use STOP as my opt-out method?

No. You can choose a reply keyword, a key press or voice opt-out on calls, or a website or phone number. Whatever you choose, you must disclose it on every call or text. Text senders must still honor all seven standard words.

Does one STOP still end every message I send?

Not always. A STOP in reply to an informational message, like a payment reminder, can end just that category. A STOP in reply to a marketing message ends all of your marketing to that person.

How fast do I have to stop texting someone who opts out?

Within a reasonable time, and no later than 10 business days after you receive the request. The FCC is asking whether to shorten that to 7. Building for same-day processing is the safer plan.

Can I send a text confirming the opt-out?

Yes, one confirmation text is allowed if it only confirms the opt-out and has no marketing. If you send it within five minutes, it is presumed to fall within the person's consent.

Do the new rules help or hurt a small business?

These changes mostly help small businesses. You get to choose a clear opt-out method. One STOP on a payment reminder no longer has to cut off the appointment reminders your customers want.

The catch: the benefit only shows up if your tools store consent by category and catch every opt-out word. Most setups we see need template changes and a CRM field or two, not a rebuild. Do it before November 25, test it from a real phone, and have your attorney sign off.

Get your follow-up automation ready for November 25

The hard part is making several tools read one opt-out list. Your reminders, missed-call text backs and AI voice calls may each run somewhere else. We build and connect that logic so every STOP is handled the same way, in every tool. See our AI lead follow-up service. Or book a free strategy call and we will walk through your setup with you.