Get started

Security and privacy

The FCC rewrote its text opt-out rules: what a STOP reply now means for your firm's client texts

On September 30, 2026, the FCC adopted FCC 26-67, replacing the strict revoke-all rule. Firms can now limit some opt-outs to one category of informational texts and designate an exclusive opt-out method, but disclosure duties apply. What changed and what to do.

Published 5 min read

By Robert Pasha

On September 30, 2026, the Federal Communications Commission adopted an order that changes what a "STOP" reply means under the Telephone Consumer Protection Act. The Report and Order, FCC 26-67, was released October 1. It replaces the strict "revoke all" rule that had been delayed until January 31, 2027.

If your firm sends automated texts, such as appointment reminders, payment reminders, or bulk updates, this is the month to look at how you handle opt-outs. The new rules are more flexible. They also come with disclosure duties that are easy to miss.

Which texts this covers

The TCPA consent rules apply to what the FCC calls robocalls. In this order, that term means any call made or text sent using an automatic telephone dialing system, or any call using an artificial or prerecorded voice. Whether a particular texting tool counts as an autodialer is a legal question that depends on how it works. Many firms treat all automated or scheduled client texts as covered and build their process to match. That is the safer habit.

What changed

Opt-outs can be limited to one category of informational messages

Under the 2024 rule, any reasonable revocation ended all robocalls and robotexts from that caller. The new order lets callers treat a revocation made in response to an informational call or text as applying only to that category of informational messages. The FCC defines informational as a message that "does not contain any advertising or telemarketing."

Marketing works differently. A revocation in response to a message that contains advertising or telemarketing revokes consent to all future advertising and telemarketing messages from that caller.

For a law firm, that means a client who replies STOP to a hearing reminder could, in principle, still receive payment reminders. A client who replies STOP to a referral request or a promotional newsletter text has opted out of all your marketing texts. One practical point: if a reminder text also promotes a service, it is no longer purely informational.

You can pick one exclusive way to opt out

Callers may now designate one of three methods as the exclusive way to revoke consent:

  • An automated, interactive voice or key-press opt-out mechanism on a call.
  • Replying to a text with any one of seven standardized words: "stop," "quit," "end," "revoke," "opt out," "cancel," or "unsubscribe."
  • A website or telephone number the caller designates to process opt-out requests.

The caller must clearly and conspicuously disclose the chosen method on the call or in the text. If you use reply texts as your exclusive method, you can satisfy the disclosure by including at least one of the standardized words in each message, such as "Reply STOP to opt out." You still have to honor all seven words. an October 2 summary on Inside Global Tech notes this one-word clarification was the main change from the draft order.

If you designate an exclusive method and disclose it properly, you are not required to process revocations made other ways. If you do not designate one, you must honor revocations made by any reasonable means.

Some rules did not change

  • Ten business days. Revocations must still be honored within a reasonable time not to exceed ten business days.
  • One confirmation text. You may send a single text confirming the opt-out, as long as it contains no marketing. If it goes out within five minutes, it is presumed to fall within the consumer's prior consent.
  • No-reply numbers. If your texting setup cannot receive replies, each text must say so and give a reasonable alternative way to opt out.

When it takes effect

The amendments take effect 30 days after the order is published in the Federal Register. The FCC said it will announce the exact date by Public Notice. As of that October 2 summary, publication had not yet happened, so check the Federal Register before you rely on a date.

The FCC also opened a further rulemaking. It asks whether to shorten the ten-business-day window to seven, require two-way texting, require a "revoke all" option for callers who use category-limited revocation, and clarify how affiliates are treated. Comments are due 30 days after Federal Register publication. More changes may follow.

Why the stakes are real for small firms

TCPA statutory damages are $500 per violation and up to $1,500 for willful violations, as Troutman Pepper Locke noted in its September 17 analysis of the draft. A reminder system that keeps texting a former client who said STOP can add up quickly.

What to do this week

  1. List every automated text you send. Sort each into informational (reminders, status updates, payment notices) or marketing (newsletters, reviews, referral asks, promotions). Anything mixed goes in the marketing pile.
  2. Decide your opt-out method. For most small firms, reply-text keywords are the simplest exclusive method. Put "Reply STOP to opt out" in every automated text.
  3. Decide whether to use the category option at all. Treating every STOP as a full stop for that number is simpler and harder to get wrong. If you use category-limited opt-outs, your disclosures and your records have to support it.
  4. Test all seven words. Send each one to your own system and confirm it stops messages and logs the request.
  5. Fix the hand-off to staff. When a client calls or emails asking you to stop texting, someone has to record it within ten business days. Write down who.
  6. Keep marketing separate. Do not add a promotion to a reminder text.
  7. Check carrier registration. If you text clients from a standard ten-digit business number, confirm your 10DLC carrier registration is in place before you send. LawMOR, for example, honors STOP opt-outs automatically and blocks texting on the firm's number until 10DLC registration is approved.

This post is general information, not legal advice; check the final order, your state's rules, and any state telemarketing laws that apply to you.

Sources