The FCC Is About to Let You Name One Way to Opt Out

What the draft actually changes#

The FCC circulated a draft Report and Order and Further Notice on 9 September 2026, tentatively set for a vote at the 30 September 2026 open meeting. It is CG Docket No. 02-278, circulation number FCC-CIRC 2609-05.

The headline change reverses the rule in force since April 2025. Today a sender must honor a revocation made by any reasonable method. The draft would let a sender name one method and stop there.

Our own TCPA guide states the current rule plainly, and that sentence is what this document would rewrite. Nothing has changed yet.

• The draft would amend section 64.1200(a)(10) so callers may designate any of three listed methods as the exclusive means to revoke consent (FCC draft, para 15, read 12 September 2026).
• A sender that designates one of the three is not required to process revocation requests made by any other means. A sender that designates nothing must keep honoring any reasonable manner (para 16).
• The Commission states the document remains under consideration and subject to change, and does not constitute official action.
• Update, 2 October 2026: adopted on 30 September as FCC 26-67, with two changes from this draft. Read what moved between draft and final.

The three methods, and the price of picking one#

The three permitted methods are an automated voice or key-press opt-out on a call, a reply to an incoming text using a standardized word, or a website or phone number the sender provides to process opt-out requests.

There is one firm condition. The sender must clearly and conspicuously disclose the designated method on the call or in the text. The FCC specifically declined to let senders decide when and how to disclose it.

So the relief is real and it is not free. Designating a method puts a disclosure line inside your copy, on every message the rule covers.

• If you designate reply text, the closed list is stop, quit, end, revoke, opt out, cancel, or unsubscribe (draft rule text for 64.1200(a)(10)(ii), read 12 September 2026).
• Miss the disclosure and you are back under the any-reasonable-means standard, where an unusual phrase on an unusual channel still counts.
• Disclosure costs characters, and characters are the unit that per-message vendors bill: see how a credit is counted before you decide where that line goes.
• Blue Reacher prices a flat $249 per line per month, so a longer opt-out disclosure changes your copy and never changes the invoice.

Sales teams get the least out of this#

The second change in the draft lets a sender read a revocation as applying only to the category of message that prompted it. Read the boundary before you plan around it.

The limit covers informational traffic only, which the draft defines as a call or text carrying no advertising or telemarketing. A revocation prompted by anything promotional still reaches all of your telemarketing.

If your program is outbound sales, that is the whole of your traffic. The relief lands with appointment reminders, fraud alerts, payment notices and outage notices, not with a pipeline campaign.

• The draft rule text limits category-scoped revocation to messages that do not contain any advertising or telemarketing (read 12 September 2026).
• The draft also reminds telemarketers that a do-not-call request reaches affiliated entities a consumer would reasonably expect to be included (para 14).
• Practical read for a sales team: treat every opt-out as global, because on your traffic it is.

January 2027 comes off the calendar#

The revoke-all provision of section 64.1200(a)(10) has been waiting since 2024 behind two waivers, most recently delayed to 31 January 2027 by order DA 26-12.

The draft does not delay it a third time. It replaces it. The revised rules take effect 30 days after Federal Register publication and supersede the delayed date.

Do not stand your preparation down on a draft. Publication timing is not fully predictable, and until the order is adopted and published the 31 January 2027 date is still live.

• The draft states the revised amendments become effective 30 days after Federal Register publication and supersede the effective date previously extended to 31 January 2027 (para 23, read 12 September 2026).
• The Further Notice sets comments at 30 days and replies at 60 days after Federal Register publication, so the argument continues past the vote.
• What to keep: your suppression build, your consent records, and the ability to switch back if the vote slips.

The proposal that would reshape tooling#

The Further Notice asks whether to delete the provision that lets a sender use a texting protocol with no reply path at all.

Today a one-way sender can comply by disclosing in every text that reply is unavailable and giving another way to opt out. That escape hatch is the thing on the table.

If it goes, send-only stacks stop being an option and every covered text needs a live inbound path attached to the same number.

• The American Bankers Association, the National Consumer Law Center and ACA International proposed the deletion in a joint letter filed 30 June 2026 (FCC draft, paras 28 and 32, read 12 September 2026).
• The notice asks how widely one-way protocols are used, whether they are used for telemarketing as well as notifications, and whether two-way should be required only on messages carrying an advertisement (paras 31 to 33, read 12 September 2026).
• An iMessage thread is two-way by construction: the reply lands in the same conversation the send came from, so the reply path is the product rather than an add-on.
• Worth noting where the category's marketing is going: one competitor changed its homepage subhead this week to read 'No "Reply STOP to opt out."' (tuco.ai, seen 12 September 2026), in the same week the FCC asked whether reply-text revocation should be mandatory.
• A designated method still has to be disclosed. The absence of a STOP line is not the absence of a revocation duty.

Ten business days, with seven on the table#

The deadline to honor a revocation is unchanged in the draft: a reasonable time, not to exceed ten business days from receipt.

The Further Notice asks whether that should drop to seven, on the theory that an automated designated method processes requests faster. The joint letter proposed seven unless the sender shows longer is reasonable.

The operational answer does not depend on the outcome. Suppress at receipt. A number that lands on your internal list the second the word arrives is inside any window the Commission lands on.

• The notice asks whether the timeframe should differ between senders who designate an exclusive method and senders who do not (para 30, read 12 September 2026).
• It also asks about reducing the list of standardized opt-out words, dropping the rebuttable-presumption analysis, and allowing one confirmation message by the end of the next business day (para 38).
• Same-second suppression is a plumbing decision, not a legal one: the reply has to reach the system that holds the send queue before the next step fires.

What to do in the next three weeks#

Designation is a decision about your copy and your suppression logic. It is not a feature you buy, and it has to be made per sender rather than per platform.

The work that pays off either way is the audit: what your messages currently say about opting out, where those words are handled, and how fast the handling happens.

Write down which method you would designate and what the disclosure line would read, then measure what it does to message length before the rule lands.

• Audit the opt-out disclosure in every active sequence, including message two onward, not just the first send.
• Separate informational traffic from promotional traffic in your consent records now, because the category relief only reads the informational side.
• Time your own suppression: send a test opt-out and measure the gap between the reply arriving and the next queued message being cancelled.
• Keep every revocation event with its timestamp, wording and channel, because the sender carries the burden of showing the request was honored.

What is decided and what is not#

Two things are worth separating. The Report and Order items would take effect on adoption plus publication. The Further Notice items are questions, and the comment cycle has not started.

Exclusive designation, category-limited revocation for informational traffic, the financial-institution fraud-alert change and the delegation to the Consumer and Governmental Affairs Bureau sit in the order.

The seven-day window, mandatory two-way texting, a mandated revoke-all method and the treatment of affiliates sit in the notice. Plan for the first group, comment on the second.

• Comment and reply dates run 30 and 60 days from Federal Register publication, and the docket is CG Docket No. 02-278 if you want to file.
• The draft delegates authority to the Bureau to rewrite the TCPA rules in plainer language, with substantive changes expressly excluded (para 22, read 12 September 2026).
• Nothing here is legal advice. The application of these rules to a specific program depends on facts only your counsel can weigh.

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