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Glossary

Revocation of consent

Revocation of consent under 47 CFR 64.1200(a)(10): which methods a consumer may use, the ten business day ceiling that runs from receipt, why a reply text also stops the calls, and which single piece of the rule the FCC has postponed to 31 January 2027.

VisionXLab 4 min read

Revocation of consent is the moment a consumer withdraws the permission a business was relying on to call or text. Under 47 CFR 64.1200(a)(10) it can be done by any reasonable method, and the caller has no more than ten business days from receipt to stop. How that permission is granted in the first place is a separate page: prior express written consent.

Which methods the rule accepts

The test is whether the consumer clearly expressed a desire not to receive further calls or text messages. Several routes qualify on their own terms: an automated, interactive voice or key press opt-out offered during a call, the words stop, quit, end, revoke, opt out, cancel or unsubscribe sent in reply to a text, and any website or telephone number the caller itself designated to process opt-outs. Use one of those and the rule treats consent as definitively revoked.

Anything else still counts when a reasonable person would understand the words as a request to revoke, so a reply reading no more calls please is a revocation. A voicemail or an email to a number or address meant to reach the caller creates a rebuttable presumption of revocation once the consumer produces evidence of it, under 64.1200(a)(11). The caller may not make one single route the only permitted way to ask, and a texting setup that cannot receive replies has to disclose that on every message and offer workable alternatives.

Where the clock actually starts

The rule gives a reasonable time not to exceed ten business days from receipt of the request. That starting point is the part worth internalising. The window opens when the request reaches the business, so every hour a stop request sits in a shared inbox, a voicemail box or an unread reply queue is spent out of the ten days rather than added to them. A company-specific do-not-call request carries the same ceiling under 64.1200(d)(3), which also says that, absent a contrary request from the subscriber, it binds the entity making the call rather than its affiliates, unless the consumer reasonably would expect them to be included.

One follow-up message is permitted. Paragraph (a)(12) allows a single confirmation text, provided it only confirms the revocation, carries no marketing or promotional content, and is the only further message sent.

A reply text also silences the dialer

Revocation attaches to the person and the number, not to the channel that carried it. The FCC Order adopted on 15 February 2024 states in paragraph 32 that a revocation made in any reasonable manner extends to both robocalls and robotexts regardless of the method used to communicate it, and gives the example of a reply text revoking consent for calls as well. A stop reply landing in a texting platform therefore has to reach the dialer, the campaign lists and anything else that could dial that number, inside the same ten days.

Source for the cross-channel point only: Federal Communications Commission, TCPA Consent Order, FCC 24-24, CG Docket No. 02-278, adopted 15 February 2024, paragraph 32, which confirms that a revocation made in any reasonable manner extends to both robocalls and robotexts regardless of the method used to communicate it, and offers the reply text example. It is cited for that sentence and nothing further.

The one piece that is still postponed

Most of 64.1200(a)(10) has been in force since 11 April 2025. One carve-out has not. The Commission has twice delayed the requirement that a revocation made in response to one type of message be treated as covering that caller's future robocalls and robotexts on unrelated matters, first to 11 April 2026 and then, by an order adopted on 6 January 2026, to 31 January 2027. Nothing in either order touches the methods, the ten business days or the bar on a single required route, so the rest of the rule applies today.

Read the two orders side by side and one thing is genuinely unsettled. The 2025 order describes the postponed reach as a revocation made in response to one type of message; the 2026 order words the same carve-out as one type of informational message. Whether the narrower 2026 wording still covers telemarketing is not answered on the face of either document. A desk that treats every stop as covering everything it sends to that number is complying with the rule under either reading.

Sources for the dates above: Federal Register, "Strengthening the Ability of Consumers To Stop Robocalls", 89 FR 82518, published 11 October 2024, effective 11 April 2025 for the addition of 47 CFR 64.1200(a)(10) and (11) and the amendments to (a)(9)(i)(F) and (d)(3) · FCC Consumer and Governmental Affairs Bureau Order DA 25-312, adopted and released 7 April 2025, granting a limited waiver of 64.1200(a)(10) to 11 April 2026 to the extent it requires a revocation sent in response to one type of message to cover that caller's future robocalls and robotexts on unrelated matters, and stating that compliance with the remaining rules is required as of 11 April 2025 · FCC Order DA 26-12, CG Docket No. 02-278, adopted and released 6 January 2026, extending that same partial waiver: the effective date of section 64.1200(a)(10) is extended to 31 January 2027 to the extent discussed therein.

What to do with a stop before you worry about the rest

Treat the request as a dated record the moment it arrives, because the deadline is measured from that moment and a dispute about it is a dispute about your own timestamps. The federal list is a different obligation with a different mechanism, covered in national do not call registry, and the defence available for a registry mistake is narrower than it sounds, covered in do not call safe harbor. That safe harbor addresses an error about the registry. It is not a cure for a revocation that was received and not acted on.

Two things a reader would reasonably want here do not exist in any primary source. There is no federal count of how often a revocation fails to reach the system that would have dialled, and no official figure for the share of TCPA claims that start this way. 64.1200 imposes no reporting duty that would produce either number and the Commission publishes neither, so no figure of that kind appears above. The numbers that circulate for both trace to vendor commentary rather than to a study.

Sources: Telephone Consumer Protection Act rules, 47 CFR 64.1200(a)(10), (a)(11), (a)(12) and (d)(3), text read 20 September 2026 in the GPO CFR XML at govinfo.gov, supporting the any reasonable method standard, the methods that qualify on their own terms, the treatment of other wording a reasonable person would understand, the rebuttable presumption for a voicemail or email, the disclosure owed when a texting protocol cannot receive replies, the ten business days from receipt, the single permitted confirmation text, and the company-specific do-not-call provisions including the default position on affiliates · Federal Communications Commission, TCPA Consent Order, FCC 24-24, CG Docket No. 02-278, adopted 15 February 2024 and released 16 February 2024, paragraph 32, supporting only the statement that a revocation extends to both robocalls and robotexts regardless of the method used to communicate it · effective dates and waivers as listed in the source note above. The eCFR and Federal Register web pages both redirected to an access interstitial on the day of writing, so the rule text was taken from the GPO XML and the effective date from the Federal Register document API.

Questions this page answers

By any reasonable method that clearly expresses a desire not to receive further calls or text messages, under 47 CFR 64.1200(a)(10). Some methods count automatically: an automated or key press opt-out on a call, the words stop, quit, end, revoke, opt out, cancel or unsubscribe sent in reply to a text, or the website or phone number the caller itself set up for opt-outs. Other wording in a reply text still counts if a reasonable person would understand it as a request to revoke, and a caller may not make one single route the only permitted way to ask.

Within a reasonable time not to exceed ten business days from receipt of the request, under 47 CFR 64.1200(a)(10). The clock starts when the request reaches the business, not when it reaches the dialer, so routing time inside the company is spent out of that window rather than added to it. A company-specific do-not-call request carries the same ten business day ceiling under 64.1200(d)(3), which also provides that, absent a contrary request, it applies to the entity making the call and not to affiliates unless the consumer reasonably would expect them to be included.

Yes. Paragraph 32 of the FCC Order adopted 15 February 2024 confirms that when consent is revoked in any reasonable manner, the revocation extends to both robocalls and robotexts regardless of the method used to communicate it, and gives the example that a reply text revokes consent for calls as well as texts from that caller. How far a revocation reaches across unrelated subject matter is the one piece of the rule the Commission has not yet put into force, with the current waiver running to 31 January 2027.

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