TCPA revocation of consent is the rule that decides what happens when a customer texts STOP to your business, and the Federal Communications Commission is scheduled to change it on September 30, 2026. The rule in force now says a customer can opt out any reasonable way, and you have at most ten business days to stop. The draft order would let a business name the opt-out methods it accepts, as long as it discloses them in every message, and would let an opt-out from an appointment reminder stop only reminders rather than everything. For a service business that texts customers from a scheduling or marketing tool, the practical work is the same either way: know which of your messages are informational and which are marketing, make STOP work in every thread, and be able to show when each opt-out was honored. This post sets out what applies today, what the draft changes, and the order to check it in. It describes the rules; it is not legal advice.
In short
- Since April 11, 2025, an opt-out made any reasonable way must be honored within 10 business days, and a single confirmation text is allowed if sent within 5 minutes with no marketing.
- The revoke-all provision is delayed to January 31, 2027, and the FCC's draft for its September 30, 2026 meeting would narrow it.
- The draft lets a business designate any of 3 opt-out methods as exclusive, provided each message discloses them.
- WebRecon counted 2,810 TCPA lawsuits filed in 2025, up 0.8% on 2024. The statute allows $500 per violation, up to three times that if willful.
What the TCPA revocation of consent rules require today
The FCC adopted the current rules in its 2024 consent order, published in the Federal Register on March 5, 2024, and they took effect on April 11, 2025. They apply to what the FCC calls robocalls: calls or texts sent with an autodialer, and calls using an artificial or prerecorded voice. A texting platform that sends reminders and promotions from a list is in scope.
What they require, in plain terms:
| Requirement | What it means for a business that texts |
|---|---|
| Any reasonable method | A reply of "stop," "quit," "end," "revoke," "opt out," "cancel" or "unsubscribe" is a revocation. Other clear requests can count too. |
| Ten business days | The opt-out must be honored within a reasonable time, no more than ten business days from receipt. |
| One confirmation text | Allowed if it only confirms and carries no marketing. Within five minutes, it is presumed fine. |
| No-reply numbers | If replies are technically impossible, every text must say so and give another way to opt out. |
| Revoke-all | Delayed to January 31, 2027 by a bureau order of January 6, 2026. |
The exposure is why small businesses should care. The statute gives a consumer a private right to $500 in damages for each violation, and a court may increase that to up to three times the amount for a willful or knowing violation. WebRecon's year-end count found 2,810 TCPA suits filed in 2025, up 0.8% on the year before, and 68% of the TCPA suits filed in December were putative class actions. A missed STOP multiplied across a customer list is what those class actions are made of.
What the September 30 draft would change
On September 9, 2026 the FCC released a fact sheet and the draft text of a Report and Order and Further Notice of Proposed Rulemaking, circulated for its September 30 open meeting. The document says itself that the issues "remain under consideration and subject to change." As drafted, it does three things a service business will notice.
It narrows the revoke-all rule. A business "may interpret a revocation request made in response to an informational call or text message" as applying only to that category of informational messages. A STOP sent in reply to a marketing text still ends all future marketing texts from that business.
It lets a business name its opt-out methods. A business may designate one or more of three methods as the exclusive way to revoke: an automated voice or key-press option on a call, a reply with one of the standard words, or a website or phone number the business provides. The business must disclose the designated method "clearly and conspicuously" on the call or in the text. A business that designates is "not required to process revocation requests made by any other means." A business that does not designate must keep honoring any reasonable method.
It asks about the next round. The further notice seeks comment on shortening the ten-business-day window, where a joint filing from the American Bankers Association, the National Consumer Law Center and ACA International suggested seven business days, on requiring two-way texting, and on requiring a single method to revoke consent to everything.
How to check your texting before either date
- List every automated text you send. Appointment confirmations, reminders, review requests, quote follow-ups, seasonal offers. Mark each one informational or marketing. The draft treats them differently, and so, already, does your consent.
- Send STOP to your own number. From a personal phone, reply STOP to a reminder and to a promotion, then try "please stop texting me." Note what the platform does with each, and how long it takes.
- Make the disclosure part of the template. If you plan to rely on a designated method once the order is final, the draft requires it to be stated in the message itself. "Reply STOP to opt out" in every text is the cheapest version.
- Check the confirmation text. One message, no coupon, no link to a sale, sent within five minutes. Many platforms add a promotional footer by default; take it off that message.
- Find the opt-outs that do not arrive by text. A customer who says "take me off your list" to a technician, in an email or on a call is still revoking under today's rule. Decide who writes it down and where, and set a check inside the ten business days.
- Keep a record. For each opt-out: the date received, the words used, the date honored. If a claim ever arrives, that log is the evidence.
The mistake most businesses make at step 5
They treat the texting tool's STOP handling as the whole compliance process. It covers step 2 and nothing else. Under the rule in force, a request made at the counter or in a voicemail counts if it is reasonable, and a business that keeps texting after one has no automated log to point to. Until the draft becomes a final order and a business chooses to designate its methods, the offline opt-out is the gap. After it, the gap moves to the disclosure: a designated method that is not stated in the message does not protect the business.
We build email and text message marketing with STOP honored before the next message and consent recorded at the point it was given, which is how the system is built rather than a legal opinion. For anything about your own obligations, ask a lawyer who practices TCPA; the rule is a federal one, and a Michigan business is covered by it the same as any other. More on running the phone and text side of a local business is on the services page.
What to watch on September 30
Whether the Commission adopts the draft as circulated, and when the order is published in the Federal Register; the draft sets comments on the further notice at 30 days after publication. Until then, the ten-business-day rule, the keyword list and the single confirmation text are the law, and the January 31, 2027 date for revoke-all stands.
