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TCPA Opt-Out Requirements: Pick Your Method From November 25

From 25 November 2026, a business may name the only opt-out methods it has to honor for its robocalls and texts: an automated voice or key press opt-out on the call, reply words such as STOP, or a website or phone number it designates, as long as every call or text discloses them. Requests must still be honored within 10 business days. If your AI agent sells, that buys you little: the FCC’s order leaves the opt-out an artificial-voice sales call owes exactly as it was.

TCPA opt-out requirements from 25 November 2026: callers may name exclusive opt-out methods if every call or text discloses them, while AI sales calls keep the automated in-call opt-out and the do-not-call list

The order was published in the Federal Register on 26 October 2026, but until 25 November the rule in force still says callers “may not designate an exclusive means” to revoke consent. On 27 October, Google’s AI Overview for “tcpa opt out requirements” told me callers “may designate” exclusive opt-out methods, in the present tense. Act on that this month and an email that says “stop calling me” becomes a revocation you ignored.

From 25 November you can pick the opt-out you must honor. If your AI agent sells, the rules already picked the in-call one for you.

Key numbers

ItemNumber
Date callers may first name an exclusive opt-out method (FCC 26-67)25 November 2026
Order published in the Federal Register (91 FR 67214)26 October 2026
Delayed revoke-all date the order replaces31 January 2027
Opt-out methods a caller can make exclusive (in-call voice or key press, reply words, a website or phone number)3
Reply words a text sender must honor (a text may name just one)7
Time to honor an opt-out (unchanged by the order)10 business days
AI sales call opt-out offer, after naming the business (47 CFR 64.1200(b)(3))Within 2 seconds
Confirmation text presumed within consent if sent within5 minutes
Honor window suggested in the joint letter (unless a longer period is shown reasonable)7 business days
Comments due on the further notice (replies 28 December 2026)25 November 2026
Statutory damages per call without consent (up to three times if willful or knowing)$500
FCC ruling that AI voices are artificial voices (FCC 24-17)8 February 2024

Read on 27 October 2026 from FCC 26-67 and its further notice in the Federal Register (91 FR 67214 and 67239), 47 CFR 64.1200 on eCFR, 47 U.S.C. 227 on LII and the FCC’s page for FCC 24-17.

What changes on 25 November

The order, FCC 26-67, adopted on 30 September (we covered the draft in our preview of the vote), rewrites the opt-out paragraphs of 47 CFR 64.1200, (a)(10) to (a)(12). A caller may make any of three methods its exclusive way to revoke consent: an automated, interactive voice or key press-activated opt-out mechanism on a call; a reply text using one of seven words, “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel” or “unsubscribe”; or a website or telephone number it designates.

The method must be disclosed clearly and conspicuously on the call or in the text, and the FCC refused to let callers choose when and how. A text can name a single word, such as “Reply STOP,” as long as the sender honors all seven. A caller that designates a method need not process requests made any other way. One that does not stays on today’s standard: any reasonable means.

Two more changes matter. An opt-out from an informational message, one with no advertising or telemarketing, can be limited to that category: stopping payment reminders need not stop appointment reminders, the FCC’s own example. An opt-out from a marketing call or text still revokes consent to all of your marketing calls and texts. And the rewritten (a)(12) still protects a text that merely confirms an opt-out, presumed fine if sent within five minutes, but drops the line that let it ask which messages the person meant.

Ten business days stays the limit, and the order replaces the revoke-all provision that had been pushed to 31 January 2027.

Why AI sales calls gain the least

Since 8 February 2024 the FCC has treated an AI-generated voice as an artificial voice under the TCPA (FCC 24-17). That puts your agent under paragraph (b), which the order did not touch. Every artificial-voice call must open with the business’s registered name. A call that sells must then offer an automated, interactive voice or key press opt-out within two seconds of that introduction. When someone uses it, the mechanism must record the number on your do-not-call list and end the call immediately, and a voicemail must leave a toll-free number that reaches the same mechanism.

The order says the change “does not alter the existing opt-out methods” for calls that advertise or telemarket. Paragraph (d)(3) stays as well: a business calling for telemarketing must record a residential subscriber’s request not to be called and honor it within 10 business days, and the paragraph names no channel. My reading: if your agent sells, a “stop calling me” that arrives by email or through your technician still goes on the do-not-call list, whatever method you designate. Each sales call made after consent is revoked can cost $500 under the statute, up to three times that if a court finds it willful or knowing.

What gets repeated

From now on we only have to honor STOP.

Not before 25 November, and not for the in-call opt-out or the do-not-call requests that sales calls owe.

What the order says

Callers may designate an exclusive method if they disclose it clearly and conspicuously on the call or in the text.

It does not alter the opt-out methods required for calls that advertise or telemarket.

Where it pays: reminders and texts

Reminders, job confirmations and payment notices with no offer in them are informational, and there the change is real. A home services company can make the in-call opt-out the exclusive method for its AI reminder calls, say so on every call, and file each opt-out under the category it answered. The same goes for the booking confirmations an AI answering service for HVAC sends. Texts work the same way with reply words, and a sender on a no-reply number must say so in every text and offer another way out.

The catch is the word informational. Add one offer to a reminder and the call includes an advertisement, which puts it under the sales rules above. Our guide to AI calls to past customers shows where that line sits.

The opt-out has to write somewhere

Naming the in-call opt-out as your exclusive method only helps if it works, and on sales calls paragraph (b)(3) says it must record the number by itself. When I read the Retell, Vapi, Bland and GoHighLevel documentation for our September piece on AI voice agent opt-outs, none described writing a spoken “stop calling me” to a suppression list without a field, flow or sync you build yourself.

Test it: say “stop calling me” on a call in your own words, then check that the next campaign skips the number, whichever of the AI voice agent platforms you run.

2seconds after naming the business for an AI sales call to offer its opt-out
10business days to honor an opt-out, unchanged by the order
7reply words a text sender must honor, even if its texts name only one

What the FCC may tighten next

A further notice published the same day asks whether 10 business days should shrink now that callers can automate opt-outs. It cites a joint letter from the American Bankers Association, the National Consumer Law Center and ACA International that suggested seven business days unless the caller shows a longer period is reasonable, and asks whether to end no-reply texting, require a one-step way to revoke consent to all robocalls, and how opt-outs should reach affiliates. Comments are due 25 November 2026 and replies 28 December 2026.

How I would set it up

I have delivered 500+ projects, and before 25 November I would settle four things in any AI calling stack:

01

Sort every AI flow: sales or informational

If a script can mention a price, a promotion or an upsell, treat the whole flow as a sales flow.

02

Script the sales opt-out to the second

Name the business first, offer the voice or keypad opt-out within two seconds, write the number to your do-not-call list and hang up. Keep a route for requests that arrive by email or through staff.

03

Designate, then disclose every time

For reminders and texts, choose your exclusive methods for 25 November and put the disclosure in every script and template. Store opt-outs by category, not as one flag.

04

Process opt-outs the same day

Ten business days is the ceiling and seven is on the table. An opt-out that writes the moment it is heard meets both.

It is the opt-out layer of the TCPA-compliant AI calling setup we build: the in-call opt-out wired to your do-not-call list, and a log of every request.

The bottom line

From 25 November you can pick the opt-out methods you must honor, a real simplification for reminders and texts. For AI sales calls the order kept the two-second opt-out and the do-not-call list, so the work is unchanged: make the opt-out write to a list, disclose it every time and honor requests fast. Calling outside the US? The rules work differently in Canada and South Africa. I am not a lawyer, and this is not legal advice.

Frequently Asked Questions

On 25 November 2026. The FCC adopted the order, FCC 26-67, on 30 September 2026, released it on 1 October and published it in the Federal Register on 26 October. Until then the rule in force says callers may not designate an exclusive means to revoke consent, so any reasonable method counts.
Three: an automated, interactive voice or key press-activated opt-out on a call; a reply text using stop, quit, end, revoke, opt out, cancel or unsubscribe; or a website or telephone number the caller designates. The method must be disclosed clearly and conspicuously on the call or in the text. A text may name just one of the words, but the sender must honor all seven.
Yes, when they sell, and when they reach a home landline under one of the rule’s no-consent exemptions. The FCC treats AI-generated voices as artificial voices, and an artificial-voice call that includes an advertisement or constitutes telemarketing must offer an automated voice or key press opt-out within two seconds of identifying the caller, record the number on the caller’s do-not-call list and end the call. The new order does not change that.
Ten business days from receipt, before and after 25 November 2026. The FCC is asking whether to shorten it, and a joint letter from banking, consumer and collections groups suggested seven business days. Comments are due 25 November and replies 28 December 2026.

Is your AI agent’s opt-out ready for 25 November?

On a 30-minute call I will check what your AI calls and texts disclose, where a spoken stop goes and whether your do-not-call list hears it, and tell you what to fix before the rules change. Book it here: cal.com/zeeshanwaheed/30min.

Book a 30-Minute Call

Or email [email protected].