The Federal Communications Commission (FCC) has a new set of rules covering the rights of consumers to not be reached by companies without their permission.
To find out more about them we reached out to Paul St. Clair, who is Head of Compliance at Convoso. Here are his explanations, insights, and recommendations.
Q. What is this regulation/rule and what are the key details for contact centers?
The FCC issued new rules under the Telephone Consumer Protection Act (TCPA) in February 2024, making it easier for consumers to revoke consent for robocalls and texts.
The new TCPA rules require businesses to honor opt-out requests across communication channels. The rules also require faster timelines for contact centers to process consumer opt-out requests, along with other measures that will impact contact center operations.
These rules were set to go into effect in April 2025. However, the FCC delayed by one year the aspect of the rule that required honoring opt-out requests across communication channels. This cross-channel rule is now effective beginning in April 2026.
“The ‘cross-channel’ opt-out is the biggest change from the existing framework…” —Paul St.Clair
It is vital for contact centers to know the remaining aspects of the new TCPA rules that went into effect on April 11, 2025. Contact centers should not only be aware of these updates but they should be marking operational changes to adapt.
Q. What are the changes from the existing TCPA regulations?
The “cross-channel” opt-out is the biggest change from the existing framework, and there is a reason why the FCC delayed this part of the new rules. Businesses will need to adapt systems and processes across different business units that conduct marketing or even just informational outreach, such as IT teams sending authentication messages, to accommodate the new opt-out requirements.
Although contact centers have another year to adapt to the cross-channel requirement, there are several key changes from the existing regulations that went into effect in April 2025:
- Any reasonable method is valid. Consumers may opt out using any “reasonable” method, such as verbally over the phone, email, texting, or potentially even at a brick-and-mortar location of your business.
- It’s entirely possible a court could find that consumers can call your main phone line, and not just customer service or a marketing number, to revoke their consent and that this is a reasonable method.
- Texting with consumers. If consumers can’t respond to texts due to technical limitations, such as the originating numbers being no longer assigned, businesses must disclose this and provide alternative opt-out instructions.
- Faster processing. Businesses must honor opt-outs within 10 business days instead of the previous 30-day timeline.
- Limited clarification message. Companies may send one message to confirm an opt-out request within five minutes of receiving the communication. This clarification message may include asking whether the consumer wants to opt out of just marketing or informational communications as well.
Q. What reasons led to the creation of the new rules?
The FCC created the new TCPA consumer rules in response to growing consumer frustration, legal inconsistencies, and regulatory concerns over unwanted calls and texts.
Many businesses made it difficult for consumers to revoke consent, requiring specific procedures or ignoring opt-out requests made through reasonable means. The FCC’s order will ensure that revocation must be honored through any reasonable method.
“…contact centers should be very deliberate about the operational updates they are making…”
Legal disputes and inconsistent court rulings also contributed to the rule’s creation. Some courts upheld broad consumer opt-out rights, while others allowed businesses to impose stricter revocation conditions.
Q. Are there any challenges in complying with these rules?
Complying with the new TCPA consumer rules presents significant challenges for businesses that rely on outbound calls and texts.
- The requirement to honor opt-outs through any reasonable method and within certain timelines means companies must implement robust tracking systems to capture and process revocation requests within the new 10-day timeline.
- Even more complicated, businesses must make their own determinations as to what is a “reasonable” opt-out request. Contact centers should create or edit their current opt-out policies to reflect that consumers can opt out verbally, via text, email, or even via other channels such as social media, so long as those methods are “reasonable.” Training employees and agents to recognize and act on all reasonable opt-outs to avoid compliance risks will be key.
- The FCC’s rules do not spell out the definition of reasonable very clearly. This grey area presents opportunities for litigants to bring lawsuits under the TCPA’s private right of action. As most businesses know, operating under uncertainty like this presents a range of challenges, and not just legal risk. Without clear rules on what constitutes a “reasonable” opt-out method, businesses may over-comply and opt out more consumers than strictly necessary, presenting challenges to reaching business goals.
The changes in April 2026 present even more complications. The requirement to honor revocation across all channels will require coordination between an organization’s departments and potentially its technology systems.
I have spoken with a number of organizations that are trying to figure out how to get different databases to talk to each other, and who are looking at wholesale migration to new platforms to comply with the new cross-channel rules.
“Make revocation simple and accessible, whether through a live agent, email, website form, or automated response system.”
This update is a strain on financial and other business resources and contact centers should be very deliberate about the operational updates they are making in response to the new rules.
Compliance also poses additional challenges. These include recordkeeping across channels and deciding which of your organization’s communications are consented and exempted based on customers’ opt-out requests.
Failure to properly track revocations could lead to costly lawsuits or fines. This makes it essential for companies to audit and refine their compliance processes before the rule takes full effect.
Q. What are your best practices compliance recommendations?
To comply with the new TCPA rules businesses should adopt the following best practices:
- Educate all employees. Ensure that the entire organization is aware of these key TCPA changes.
- Implement real-time opt-out tracking. Use an integrated CRM and dialer system that instantly logs and enforces revocation requests across all communication channels (calls, texts, emails). Ensure that all opt-outs are synchronized across systems to prevent accidental re-contact.
- Train agents on immediate compliance. Educate sales and support teams to recognize and act on any verbal or written opt-out request immediately without requiring consumers to take additional steps. Provide scripts and role-play scenarios to reinforce compliance.
- Simplify text message opt-outs. Configure SMS platforms to automatically process opt-out phrases considered to be mandatory: “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” and “unsubscribe.” Immediately halt further messages, besides any confirmatory communications within five minutes. Conduct regular system tests to ensure compliance.
- Audit and monitor compliance. Regularly review call recordings, text logs, and CRM records to confirm opt-out requests are being processed correctly. Conduct internal compliance audits and stay updated on regulatory changes.
- Provide a clear and easy opt-out process. Make revocation simple and accessible, whether through a live agent, email, website form, or automated response system. Avoid placing unnecessary barriers to opting out.
- Legal and compliance review. Work with TCPA attorneys or compliance experts to assess policies, procedures, and technology systems to mitigate risk and ensure full compliance with the new regulations.
Fortunately, the postponement of the consent revocation provisions will give them more time to be ready for them, with methods in place and staff including agents trained, when these come into effect next year. But companies need to act now on the other new changes to ensure immediate compliance.
The Silver Lining in the New FCC Rules?
Complying with the FCC’s new consumer rights rules may have an unexpected benefit for organizations. Namely having to tear down the walls that all too often exist between channels and the contact center and other departments.
So, we asked Paul St. Clair “Could this open the door to more – and profitable – omnichannel coordination and integration?”
“Following the FCC’s updated TCPA rules isn’t just about checking a compliance box,” says Paul. “It’s also a chance to rethink how teams work together.
“The new rules make it clear that businesses need to offer simple, straightforward ways for people to opt out. While that might seem like a constraint at first, it actually pushes companies to better connect the dots between their contact centers, marketing, and customer service efforts.
“It’s a false dichotomy in the industry that giving consumers more power to revoke consent leads to less quality contact. Instead, businesses that offer clear opt-out methods will better filter out poor quality leads and truly reach those interested in hearing from their business.”
By integrating consent management across voice, SMS, email, and digital platforms, businesses can unify their data strategies, reduce redundant outreach, and focus on high-intent consumers, Paul points out. In doing so, companies can not only boost compliance but also improve customer trust, campaign performance, and long-term ROI.
“Bottom line: this is a good moment to break down internal barriers and build a more flexible, consumer-friendly way to communicate,” says Paul.
