TCPA Consent Order 2025: What Businesses Need to Know Before April 11

What is the new TCPA Consent Order?

The TCPA Consent Order, adopted by the Federal Communications Commission (FCC), takes effect on April 11, 2025, updating requirements for how businesses must process consent revocation and opt-out requests for robocalls and robotexts. These changes reinforce consumer rights under the Telephone Consumer Protection Act (TCPA) and clarify compliance regulations for businesses using calls, texts, or automated messaging.

TCPA Compliance 2025 – businesses must ensure their opt-out processes meet the new rules to avoid regulatory penalties.

⚖️ Key Changes in the 2025 TCPA Consent Order

1. Revocation of Consent Must Be Easier for Consumers

• Consumers may revoke prior express consent at any time using any reasonable method that clearly expresses their desire not to receive further calls or text messages.
• The following opt-out methods are considered per se reasonable:
  • Using an automated voice or key-press opt-out on a call.
  • Replying to a text message with any of the following: "stop", "quit", "end", "revoke", "opt out", "cancel", "unsubscribe" or any other words that a reasonable person would understand as a request to revoke consent.
  • Submitting a request via a designated website or telephone number.
• Businesses cannot limit how consumers revoke consent (e.g., requiring a web form only is non-compliant).
• If a consumer uses any of these methods, the caller must treat the consent as definitively revoked and cannot send additional calls or texts.

"A called party may revoke prior express consent, including prior express written consent, to receive calls or text messages made pursuant to paragraphs (a)(1) through (3) and (c)(2) of this section by using any reasonable method to clearly express a desire not to receive further calls or text messages from the caller or sender.

Any revocation request made using an automated, interactive voice or key press-activated opt-out mechanism on a call; using the words 'stop,' 'quit,' 'end,' 'revoke,' 'opt out,' 'cancel,' or 'unsubscribe' sent in reply to an incoming text message; or pursuant to a website or telephone number designated by the caller to process opt-out requests constitutes a reasonable means per se to revoke consent."

📜 (47 CFR § 64.1200(a)(10))

2. Rebuttable Presumption for Other Revocation Methods

• If a consumer uses another channel to revoke consent (such as leaving a voicemail or sending an email), there is a “rebuttable presumption” that the consumer’s request is valid.
• This means that, unless the company can show otherwise, the law will assume the consumer successfully revoked consent.

“The use of any other means to revoke consent not listed in paragraph (a)(10), such as a voicemail or email … creates a rebuttable presumption that the consumer has revoked consent when the called party satisfies their obligation to produce evidence that such a request has been made, absent evidence to the contrary. In those circumstances, a totality of circumstances analysis will determine whether the caller can demonstrate that a request to revoke consent has not been conveyed in a reasonable manner.”

📜 (47 CFR § 64.1200(a)(11))

3. One-Time Confirmation Text

• After a consumer revokes consent by text, the sender may send a single confirmation text without violating the TCPA—provided it contains no marketing or promotional material.
• If this confirmation text is sent within five minutes, it is presumed valid under the consumer’s prior express consent. If it takes longer, the sender must show the delay was reasonable.
• For consumers who had opted into multiple categories of texts, the confirmation may ask whether they only want to stop some of those categories. If the consumer does not clarify, the sender must stop all messages that require consent.

“A one-time text message confirming a request to revoke consent … does not violate paragraphs (a)(1) through (2) of this section as long as the confirmation text merely confirms the text recipient’s revocation request and does not include any marketing or promotional information … If the confirmation text is sent within five minutes of receipt, it will be presumed to fall within the consumer’s prior express consent. If it takes longer, however, the sender will have to make a showing that such delay was reasonable…”

📜 (47 CFR § 64.1200(a)(12))

4. Businesses Must Process Opt-Out Requests Faster

• Previously, businesses had 30 days to process opt-outs. As of April 11, 2025, all opt-out requests must be honored within 10 business days of receipt.
• If the caller uses a third party to maintain do-not-call records, the original caller is still liable if the request is not properly honored.
• The caller must obtain the consumer’s permission before sharing or forwarding any do-not-call request to another entity.

“If a person or entity making an artificial or prerecorded-voice telephone call pursuant to an exemption under § 64.1200(a)(3)(ii) through (v) or any call for telemarketing purposes … receives a request from a residential telephone subscriber not to receive calls from that person or entity, the person or entity must record the request and place the subscriber’s name, if provided, and telephone number on the do-not-call list at the time the request is made. … Persons or entities making such calls … must honor a residential subscriber’s do-not-call request within a reasonable time from the date such request is made. This period may not exceed ten (10) business days from the receipt of such request…”

📜 (47 CFR § 64.1200(d)(3))

5. Package Delivery Opt-Out

• Package delivery companies that send automated delivery notifications must honor opt-out requests within 6 business days.

"The package delivery company must offer package recipients the ability to opt out of receiving future delivery notification calls and messages and must honor an opt-out request within a reasonable time from the date such request is made, not to exceed six business days"

📜 (47 CFR § 64.1200(a)(9)(i)(F))

🎙️ What the Industry is Saying

As businesses prepare for TCPA compliance in 2025, legal experts and industry professionals are weighing in on the impact of the new consent revocation rules.

Uncertainty in Interpreting Opt-Out Requests

"Ironically, the FCC prefaced this order by repeatedly stating its rule changes would “make clearer to callers and consumers” how consent could be revoked and that its order would “remove uncertainty.”"

- Adam D. Bowser ArentFox Schiff

One of the biggest concerns with the new consent revocation rules is the lack of clarity on what constitutes a "reasonable" opt-out request. If consumers can revoke consent in any natural language, businesses may face ambiguous requests that are difficult to interpret.

For example, if a consumer replies to a marketing text with:

"I'm not sure I want to receive this"
"Not feeling these messages anymore"
"This is getting old"

Are those valid opt-out requests? Without clear parameters, companies face the risk of non-compliance penalties if they misinterpret a message or fail to process it correctly.

How Systems Will Handle Revocation Language Ambiguity

"This creates significant uncertainty for senders who will now have to train systems to recognize this consumer 'desire' from natural language text backs, and will likewise impose costs on firms to modify their systems to recognize and process these requests."
🔗 Womble Bond Dickinson

This change introduces a major challenge for businesses that rely on automation. Previously, opt-outs followed a structured format (e.g., "STOP"), but the new rules allow consumers to revoke consent with any reasonable wording. This means companies must upgrade text recognition systems and invest in manual review processes or AI to ensure compliance. The added complexity could increase operational costs, particularly for businesses handling large-scale SMS campaigns.

💡 Solution: At Formcertify, we've introduced OptOut AI to help businesses stay compliant with the new FCC requirements. It detects opt-out requests in real-time - ensure you never miss an opt-out and avoid the risk of TCPA lawsuits. Learn more

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Sources

• FCC-24-24A1.pdf
• DA-24-1068A1.pdf
• Strengthening the Ability of Consumers to Stop Robocalls