Opt-out rules for texts change November 25

On November 25 the FCC’s rules for opting out of business calls and texts change. If you send appointment reminders, review requests or promotions from a CRM, use this week to put an opt-out line in every template, test all seven opt-out words, and sort your texts into informational and marketing. This is not legal advice; confirm with counsel before you change a live campaign.

The FCC adopted the Report and Order on September 30, 2026 (CG Docket No. 02-278) and published it in the Federal Register on October 26 as document 2026-21821. In the Commission’s own summary, it will “allow callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed, allow callers to designate an exclusive means to revoke consent”. Whether each CRM text counts as one is a question for your lawyer; assume it does.

Informational or marketing: the line that now matters

The order defines an informational call or text as one “that does not contain any advertising or telemarketing.” An appointment reminder, an “our technician is on the way” text and a payment reminder are informational. A seasonal discount or a new-service announcement is marketing.

That line decides how far a STOP reaches:

• A reply to an informational text may be treated as covering only that category. The FCC’s own example is a customer who opts out of payment reminders but would still want fraud alerts or appointment reminders.
• A reply to a marketing text revokes consent to all future marketing calls and texts from you.

Two traps. One coupon line turns a reminder into a marketing text, because it now carries an advertisement. And the order never mentions review requests, so decide with counsel where yours fall; one that pairs the ask with a discount reads like marketing. Not legal advice; confirm with counsel which category each template belongs to.

What naming one opt-out method means in practice

Until now a business had to honor an opt-out made “using any reasonable method”. From November 25 you may designate one of three methods as the only one you must process: a key-press or voice opt-out on an automated call, a reply text using a standardized word, or a website or phone number you set up for opt-outs.

The condition is that the method is disclosed “clearly and conspicuously” on the call or in the text. The FCC refused to let businesses choose when to tell people, so that means every message, not a line in your terms. For texts, naming one word is enough, as long as all seven still work.

A business that designates nothing keeps the old duty to honor any reasonable request. Even with a method designated, we tell clients to act on a “please stop texting me” typed in plain words; the customer meant it, and state laws can add their own rules. Not legal advice; confirm with counsel before you rely on an exclusive method.

What changes and what stays the same

The FCC says the order imposes “no new compliance obligation.” The changes are permissions; the duties you had stay.

Topic	The rule from November 25	Status
Naming one opt-out method	Allowed, if each message discloses it	New
Opt-out words on texts	All seven count	Same
STOP to an informational text	May cover only that category	New
STOP to a marketing text	Ends all marketing from that business	Spelled out
Deadline to honor an opt-out	No more than ten business days	Same
Confirmation text	Allowed if it only confirms	Same
Texts that cannot take replies	Must say so and give another way out	Same

The order changes the FCC’s rule only, not state telemarketing laws or your texting provider’s terms. Not legal advice; confirm with counsel which state rules reach your customers.

The open proposal: a shorter window and two-way texting

Published the same day, document 2026-21820 is a proposal, not a rule. Comments are due November 25 and replies December 28. The FCC asks:

• whether to cut the ten-business-day window, citing a joint letter from the American Bankers Association, the National Consumer Law Center and ACA International that suggests seven business days;
• whether every text should allow a reply, ending one-way texts that point people elsewhere to opt out;
• whether a business using the category rule should also offer one step that stops everything.

Nothing changes from it yet. But if a person processes your opt-outs on Mondays, make them same-day now. Not legal advice; confirm with counsel as the proposal moves.

What we are telling clients before November 25

It runs in GoHighLevel or any texting tool; agencies run it per client. Not legal advice; confirm with counsel before you switch on an exclusive method.

1. List every automated text. Workflows, reminders, review requests, missed-call text-back and the follow-up an AI receptionist sends after a call. Mark each informational or marketing.
2. Put the opt-out line in every template, not only the first message in a sequence.
3. Test all seven words from a real phone. HighLevel’s help center says SMS Do Not Disturb turns on when a contact replies with opt-out keywords, naming STOP and UNSUBSCRIBE. Send each word from a test contact and check the status changes.
4. Decide how narrow to go. In HighLevel, SMS Do Not Disturb works per channel, so a STOP to a reminder stops every text to that contact. That reaches further than the rule requires, which is allowed. Narrowing by category is a deliberate build; HighLevel says lifting a permanent SMS opt-out takes the contact texting an opt-in word such as START, or proof of opt-in sent to support.
5. Check the confirmation text: one message, within five minutes, no coupon.

See how we set up GoHighLevel CRMs, reminders and follow-up, or send your current templates through the form below and we will mark up each one before the 25th.