On October 1, 2026, the Federal Communications Commission released FCC 26-67, an order that changes how people can withdraw consent to robocalls and robotexts under the Telephone Consumer Protection Act (TCPA). It is not in effect yet. The rules start 30 days after the order is published in the Federal Register, which had not happened when Latham & Watkins summarized it on October 8.
For sales teams, the order matters wherever outreach is automated: texting steps in sequences, prerecorded voicemail drops and AI voice agents. This explainer covers US federal rules only. State laws differ, and nothing here is legal advice.
What consent revocation is
The TCPA restricts calls and texts made with an autodialer or an artificial or prerecorded voice, and in general they need the recipient's prior express consent. Anyone who gave consent can take it back. The FCC has held since 2015 that people may revoke "by using any reasonable method," and wrote that standard into its rules in 2024 (Kelley Drye). Callers currently have no more than 10 business days to process a revocation (Squire Patton Boggs).
Two earlier rulings bring common sales tools into scope. In 2022 the FCC said ringless voicemails to mobile phones count as calls made with a prerecorded voice (Faegre Drinker). In 2024 it said AI-generated voices count as artificial voices, so those calls need consent (FCC).
The statute has no blanket business-to-business exemption, and its restrictions are strictest for mobile numbers, which most business contacts now use (Wipfli). Whether a given dialer or texting platform counts as an autodialer depends on how it works, which is a question for counsel.
Why revoke-all was replaced
In 2024 the FCC also adopted a "revoke-all" rule: an opt-out in response to one type of call or text would cover every future robocall and robotext from that caller, on any subject. The FCC postponed it in April 2025 to April 11, 2026, then in January 2026 to January 31, 2027, while it weighed whether to change it (Burr & Forman).
What the new order changes
FCC 26-67 replaces revoke-all with a split between two kinds of message and adds an option for callers (Manatt).
- Informational messages. A caller may treat an opt-out as covering only the category of informational messages it responded to. Revoking consent to account-balance texts would not revoke consent to fraud alerts (Squire Patton Boggs).
- Marketing messages. An opt-out from an advertising or telemarketing call or text still revokes consent to all such messages from that caller. Latham & Watkins reads this as covering calls and texts from affiliated entities too.
- An exclusive opt-out method. A caller may name one of three methods as the only way to revoke: an automated voice or key-press opt-out on the call, a reply text using one of seven standard words ("stop," "quit," "end," "revoke," "opt out," "cancel," "unsubscribe"), or a designated website or phone number. The method must be disclosed clearly in each call or text, and a caller that does this need not process revocations made other ways (Day Pitney). A texter can name a single word such as "stop" in the disclosure but must honor all seven (Latham & Watkins).
Callers that do not name an exclusive method must keep honoring any reasonable request, which creates a rebuttable presumption that consent was revoked (Manatt).
A companion proposal asks whether to shorten the processing window to seven business days, require two-way texting, and clarify how opt-outs apply across affiliates and divisions (Latham & Watkins). Those are proposals, not rules.
What it means for SDR and AE workflows
Prospecting outreach is sent to sell, so it is likely to count as telemarketing, and the informational carve-out does little for it.
Once the order takes effect, a prospect who replies STOP to a covered marketing text has withdrawn consent to every marketing robocall and robotext from the company. That reaches every rep, sequence and tool that sends such messages. If the sales engagement platform, the dialer and the marketing automation system each keep their own opt-out list, those lists have to agree within the processing window.
The exclusive-method option cuts both ways. A team that adopts it needs the disclosure in every texting template and AI voice script, because the relief depends on it. A team that does not must keep honoring opt-outs that arrive any reasonable way, such as an email reply or a request to a rep on a live call, and reps need a quick way to record those where the automation reads them.
What to check in sales tools
- Whether an opt-out recorded in one tool reaches every other tool that can call or text, and how quickly
- Whether texting features recognize all seven standard words, not only STOP
- Whether templates and AI voice agents can carry an opt-out disclosure that reps cannot remove
- Whether a rep can log a verbal or emailed opt-out to the shared suppression list in one step
- Whether the platform records each revocation with a timestamp and the channel it arrived through
What commonly goes wrong
Opt-outs end up attached to a sequence or a sending number instead of the person. Duplicate contact records can share a mobile number, so suppression applied to one misses the other. And outreach to business contacts gets treated as exempt, though no blanket exemption exists.
What happens next
Federal Register publication starts the 30-day clock. Comments on the proposals are due 30 days after publication and replies 60 days after it (Latham & Watkins). Hunton notes that the order supersedes the earlier extension and expects the amended rules to take effect before January 2027.