Counsel Law

Replying STOP won't stop everything anymore: the FCC's new opt-out rules

A September 30, 2026 FCC order lets companies treat your STOP as ending one kind of message. Marketing opt-outs still end all marketing from that sender.

Counsel Editorial

Almost everyone has done it: a text you never asked for, an automated voice about a bill you do not recognize, and your thumb finds the word STOP. The legal rule that decides what happens next changed on September 30, 2026 — and the change is narrower than the headlines about “new robocall rules” suggest, but it is real, and it affects the most common way people try to make messages stop.

The Federal Communications Commission adopted an order that lets companies treat your opt-out as applying to one kind of message instead of all of them — for informational messages only — and, for the first time, lets a company name a single channel as the only way you can revoke consent. Here is what changed, what did not, and what it means the next time you reply STOP.

The rule being replaced never took effect

The Telephone Consumer Protection Act — the TCPA, 47 U.S.C. § 227 — requires consent before automated calls and texts to your cell phone, and the FCC’s rules implement it at 47 C.F.R. § 64.1200.

In 2024, the FCC adopted two rules that were about to change the STOP experience. First, companies would have to honor an opt-out made by any reasonable means — not just the channel the company prefers. Most of that took effect in April 2025. Second, an opt-out from one robocall or robotext would revoke consent to all of them from that sender — the “revoke all” rule — so that a STOP sent to a payment reminder would also shut off fraud alerts and appointment reminders. That second piece was delayed repeatedly, most recently to January 31, 2027, so it never took effect.

The new order replaces it before it ever could. A company that replies “we never had to honor that” was telling the truth — and now never will have to, in that form.

What changes, and when

The order is FCC 26-67, adopted September 30, 2026 and released October 1, 2026. Three changes matter to a reader holding a phone.

A STOP on an informational message may stop only that kind of message. If the message was informational — payment reminders, fraud alerts, appointment reminders, outage notices — the sender may now treat your opt-out as limited to that category. The FCC’s own example: under the old approach, opting out of payment reminders would also end multi-factor authentication codes and outage notices; now it does not have to. This is optional for the sender, and marketing is carved out entirely: a STOP in response to a marketing call or text revokes consent to all marketing from that sender, and do-not-call requests continue to reach affiliates where the consumer would reasonably expect it.

A company can name one official way to opt out. From three methods — an automated opt-out during the call, a reply text using any of the standardized words (stop, quit, end, revoke, opt out, cancel, unsubscribe), or a website or phone number it designates — a company may pick one or more as the exclusive way to revoke consent, and then does not have to process opt-outs sent any other way. The condition is disclosure: the designated method must be stated clearly and conspicuously in the call or text itself. For texts, naming one keyword (“Reply STOP to opt out”) satisfies the disclosure, but the sender must still honor all seven standardized words. A company that designates nothing stays under the any-reasonable-means standard.

Banks got more room to send fraud alerts. The exemption that lets financial institutions text fraud, data-breach and money-transfer alerts without prior consent previously covered only numbers the customer provided directly. It now covers numbers from a “reliable source” — including one supplied by an authorized family member or obtained from another institution. The three-message-per-event limit and the duty to honor opt-outs immediately remain.

Timing, stated precisely: the rules take effect 30 days after publication in the Federal Register, and that publication had not occurred as of October 8, 2026. Until it does, the 2024 rules — including honoring opt-outs by any reasonable means — govern. The FCC also kept the current 10-business-day window for honoring a revocation, though a companion notice asks whether to shorten it to seven and whether senders should be required to offer a “revoke all” option; those questions are open, not decided.

What a reader should actually do

  • Keep replying STOP. It still works, and for marketing it is more absolute than anything else in this area of law: one STOP ends all marketing from that sender.
  • Read what the message discloses. If it names a specific opt-out method, use that one. Under the new order, once a company has designated and disclosed an exclusive method, an opt-out sent a different way may be disregarded.
  • Be specific about what you want stopped. If the texts are informational and you want everything off, say so — “stop all messages from this number” — rather than replying a bare STOP, which the sender may read as covering only the category of the last message.
  • Keep evidence. Screenshot the message, your reply, and anything that comes after. If opt-outs keep being ignored, that record is what a complaint is built from.
  • Complain where it counts. Unwanted calls and texts go to the FCC Consumer Complaint Center (consumercomplaints.fcc.gov); telemarketing violations can also be reported to the FTC, whose do-not-call registry at donotcall.gov is free to join. A complaint is not a lawsuit, but patterns of complaints drive enforcement.
  • Do not treat a text as verification. A STOP workflow is also a social-engineering surface: if an unexpected “reply STOP to confirm” or “call this number to opt out” message arrives amid a wave of scam texts, the safer move is to contact the company through the number on your card or statement, not the channel that just texted you.

What did not change

The consent rules themselves are untouched: automated marketing calls and texts to a cell phone generally still require prior express written consent, and state law sits on top of the federal floor — several states have their own telemarketing and robotext statutes with additional registration, timing or disclosure rules, so requirements vary by state. The 2024 framework that most took effect in April 2025, including the any-reasonable-means standard for senders that have not designated an exclusive method, remains the operative baseline until the Federal Register publication starts the new clock.

The direction of the change is worth naming plainly, because both sides are visible in it. Consumer groups had argued the revoke-all rule matched what people expect a STOP to do; banks, utilities and healthcare senders argued it would cut off messages people still want, like fraud alerts. The FCC adopted the senders’ structure while preserving the marketing carve-out and the disclosure condition. What it means in practice will depend on how defensibly companies draw their “category” lines — and on complaints when they draw them badly.

The same logic shows up in another corner of the phone: when the caller is a debt collector, a separate federal rulebook applies and a different set of lines can be crossed — see What Debt Collectors Can and Cannot Do. The network’s government resources directory collects the agencies mentioned here.

This article is general information about a federal rule change, not legal advice, and it is not a substitute for advice about your own situation. The FCC’s rules are national, but several states add their own telemarketing and robotext requirements that vary by state. It is AI-written and independently AI-reviewed before publication; the review standard and this article’s findings are recorded in the network’s editorial review log.

Frequently asked questions

Is the new FCC rule in effect yet?
No. The order was adopted on September 30, 2026, but it takes effect 30 days after it is published in the Federal Register, and that publication had not happened as of October 8, 2026. Until then, the rules adopted in 2024 — including honoring an opt-out made by any reasonable means — continue to apply.
Does replying STOP still work?
Yes, and it is still the right first move. For a marketing text, a STOP ends all marketing from that sender. For an informational message, a STOP ends at least that kind of message — under the new order the sender may treat it as covering only that category, but it may not ignore it. Keep a screenshot of the message and your reply in case you need to file a complaint.
Can a company ignore an opt-out I send some other way?
Only if it has formally designated an exclusive opt-out method — an automated opt-out during the call, a standardized reply text, or a website or phone number it names for opt-outs — and disclosed that method clearly and conspicuously in the call or text itself. If it did that, it does not have to process revocations sent through other channels. If it did not, it must honor an opt-out made by any reasonable means.

Sources

  1. Federal Communications Commission — Report and Order and Further Notice of Proposed Rulemaking, FCC 26-67, adopted at the September 30, 2026 open meeting and released October 1, 2026 (category-specific informational opt-outs, exclusive opt-out methods, and the expanded fraud-alert exemption; effective 30 days after Federal Register publication) — as summarized in the commission-order analyses cited below
  2. National Law Review (Womble Bond Dickinson analysis) — 'FCC Narrows the TCPA "Revoke All" Rule, Permits Exclusive Opt-Out Methods, and Seeks Comment on Shorter Compliance Deadlines', October 7, 2026 — natlawreview.com/article/fcc-narrows-tcpa-revoke-all-rule-permits-exclusive-opt-out-methods-and-seeks
  3. Nixon Peabody client alert — 'FCC scraps "revoke all" and lets businesses pick how consumers opt out', October 7, 2026 (the three exclusive methods, the disclosure condition, the seven standardized keywords, and the pending Federal Register publication) — nixonpeabody.com/insights/alerts/2026/10/07/fcc-scraps-revoke-all-and-lets-businesses-pick-how-consumers-opt-out
  4. Day Pitney client alert — 'The FCC Changes Certain Consent Revocation Rules', October 2026 (adoption date, the changes to the any-reasonable-means and revoke-all rules, and the effective-date mechanism) — daypitney.com/the-fcc-changes-certain-consent-revocation-rules
  5. Telephone Consumer Protection Act — 47 U.S.C. § 227 (the statute: consent requirements, the national do-not-call list, and private suits for violations) — law.cornell.edu/uscode/text/47/227
  6. 47 C.F.R. § 64.1200 — the FCC's telemarketing and robotext rules, including the delivery restrictions the order rewrites — ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L/section-64.1200
  7. FCC Consumer Complaint Center — where complaints about unwanted calls and texts are filed (a complaint creates an enforcement record; it is not a lawsuit) — consumercomplaints.fcc.gov
  8. Federal Trade Commission — National Do Not Call Registry, donotcall.gov (adding your number is free; a sales call to a registered number is itself a red flag) — donotcall.gov
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