Originally published at ictdialer.com
The FCC's changes to how people revoke consent for robocalls and robotexts take effect on 25 November 2026. From that day you can treat a stop on one kind of informational message as covering only that kind, and you can name a single opt-out method that people must use. On the same day, comments close on a second round that could tighten both. If you run auto dialer software, build for 25 November now and keep the numbers adjustable.
In September we wrote that the FCC had not yet changed the revoke-all rule, because the document going around was a draft with empty date brackets. It isn't a draft any more. The Commission adopted it on 30 September as FCC 26-67, released it on 1 October, and it appeared in the Federal Register on 26 October at 91 FR 67214. Publication started a 30-day clock, and the FCC turned down a request to stretch that to 12 months.
The dates that matter
Sources: the rule at 91 FR 67214 and the proposals at 91 FR 67239, both published 26 October 2026.
The date most teams had in their plans was 31 January 2027, the delayed deadline for the old revoke-all requirement. The order says the new version of that rule "will go into effect at that time and supersede the delayed effective date." So if your opt-out project was due at the end of January, it's now due before Thanksgiving.
What's final from 25 November
Three things change for anyone sending automated calls or texts. A fourth stays exactly as it was, and that's the one people tend to get wrong.
Scoped revocation, for informational messages only. If someone replies stop to an appointment reminder, you can read that as stopping appointment reminders, not every informational message you send them. You can keep sending, say, delivery updates they haven't objected to.
Telemarketing is still all or nothing. A stop in response to a marketing call or text still revokes consent for all marketing from you. Scoping doesn't apply there.
You can name one exclusive opt-out method. Until now you had to honor a revocation made "using any reasonable method." From 25 November you can pick one of three: a key press or voice option during the call, a standard reply word in a text, or a phone number or website you provide. Pick one, and requests that come in any other way no longer have to be processed. But you must disclose the method "clearly and conspicuously" on the call or in the text. If you don't designate one, the old any-reasonable-method rule still applies to you.
The 10 business day limit hasn't moved. You still have at most ten business days to honor a revocation.
One detail will save texting teams some characters. The FCC agreed that listing all seven standard words in every message would make texts "unnecessarily lengthy." A single word, such as "Reply STOP to opt out", satisfies the disclosure. You still have to honor any of the seven words when someone uses them: stop, quit, end, revoke, opt out, cancel and unsubscribe.
Prerecorded telemarketing calls don't get to swap methods either. The order says the existing key-press opt-out required for those calls under 64.1200(b)(3) stays in place.
What's only a question, for now
Alongside the rule, the FCC published a Further Notice of Proposed Rulemaking at 91 FR 67239. None of it is law. But it tells you where the next change is likely to land, and comments close on 25 November, the same day the rule takes effect.
Left column is in force from 25 November. Right column is proposals only.
Seven business days instead of ten. A joint letter from banking and consumer groups suggested it. The FCC's reasoning is simple: if callers can now insist on an automated opt-out method, they should be able to act on it faster. It also asks whether the deadline should differ for callers who designate a method and those who don't.
The end of one-way texting. Today you can send texts people can't reply to, as long as each one says so and gives another way to opt out. The FCC is asking whether to require reply-to-revoke, possibly only for messages with marketing in them.
A "revoke all" button as the price of scoping. You could read a stop as covering one category only if you also offer a one-step way to stop everything. The FCC also asks whether that button would have to be automated.
Affiliates and separate business lines. Does a stop sent to one brand reach its sister companies?
Per number or per account. A utility trade group asked the FCC to confirm that a stop covers only the number it came from, not every number on the customer's account.
What to change in your dialer before 25 November
None of this needs a rebuild. It needs your opt-out data to carry more detail than a yes or no.
Tag every campaign as marketing or informational. Then tag informational campaigns by category. Scoped revocation is useless if your system can't tell an appointment reminder from a payment notice.
Decide whether to designate an exclusive method, and write it into every script and template. For voice broadcasts, the natural choice is a key press during the message. For texts, it's a reply word. If the disclosure isn't on the call or in the text, you can't rely on the designation.
Record how each opt-out arrived. Key press, keyword, web form or agent. If the FCC later sets different deadlines for designated and non-designated methods, you'll need that field, and you can't add it after the fact.
Measure how long revocations actually take to apply. Know your real number today. If it's already under seven business days, the proposal costs you nothing. If it relies on someone exporting a list on Fridays, find out now.
Keep the scope rules as settings, not code. The comment round could add a revoke-all requirement or change what counts as a category. Whatever you build should be adjustable in an afternoon.
In ICTDialer, people who opt out during a call are added to your User DNC list automatically, alongside the Master DNC list for national registry numbers. The work above is mostly about what you put around that: campaign categories, scripts that state the opt-out method, and a record of when and how each stop arrived. Our earlier post on building opt-out logic for the full rule covers the data model in more depth.
Should you file a comment?
If the seven-day proposal or the end of one-way texting would hit your operation hard, yes. Comments go into CG Docket No. 02-278 through the FCC's electronic filing system by 25 November, with replies by 28 December. The FCC specifically asks about costs for small businesses and for public bodies like schools that rely on one-way texting. A short filing with real numbers, such as how long revocations take you today and why, carries more weight than a long one restating the obvious.
Frequently asked questions
When do the new FCC opt-out rules take effect?
25 November 2026. FCC 26-67 was adopted on 30 September, released on 1 October and published in the Federal Register on 26 October 2026 at 91 FR 67214. It takes effect 30 days after publication.
Does this replace the 31 January 2027 deadline?
Yes. The order says the amended rule supersedes the delayed effective date that had been pushed to 31 January 2027. Plan for 25 November instead.
Can I stop honoring opt-outs that arrive by email or in a call to my office?
Only if you've designated one of the three permitted methods as exclusive and disclosed it clearly on every call or text. If you haven't, you still have to honor any reasonable method. Many operators will keep processing stray requests anyway, because it's cheaper than defending a complaint.
Does a stop to a sales text still stop all marketing?
Yes. Scoped revocation only applies to informational messages. A revocation in response to telemarketing still covers all telemarketing from that caller.
Is the seven business day deadline in force?
No. It's a proposal in the Further Notice at 91 FR 67239. The limit today is still ten business days. Comments on the proposal close on 25 November 2026.
Do I have to list all seven stop words in every text?
No. One standard word in the disclosure is enough, such as "Reply STOP to opt out." You still have to honor all seven when someone uses them.
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