How to Prepare for the New TCPA Consent Revocation Rules

[This article was originally published on the Convoso blog.]

What’s Changing as of April 11, 2025?

On April 11, 2025, new FCC rules will take effect under the Telephone Consumer Protection Act (TCPA), reshaping how businesses handle consumer opt-outs from robocalls and texts. The changes make it easier for consumers to revoke consent through any “reasonable” method, and businesses must honor these requests within 10 business days to remain compliant. Businesses can no longer rely on a few keywords and must take a holistic approach to tracking consumer consent revocation across communication channels.

For sales and lead generation teams, these new regulations require a proactive approach. Failing to comply could lead to hefty fines, legal challenges, and reputational damage. Businesses that adapt quickly will not only meet compliance requirements but also build stronger trust with consumers.

To summarize the changes that begin April 11, 2025:

• One Opt-Out Covers All Channels: If a consumer opts out via one method (text, email, or call), it applies to all communication channels, and includes marketing and informational communications.
• Any Reasonable Method is Valid: Consumers may opt out using any “reasonable” method - and no longer just keywords.
• 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.

What Companies Should Do to Stay in Compliance?

Rethinking opt-out handling

Historically, businesses often required consumers to revoke consent through specific channels, such as calling a designated number or filling out a form. The new rules mandate that companies accept opt-outs via text, email, website forms, phone calls, and even verbal requests.

Importantly, a consumer's revocation request will now apply universally across all communication channels and purposes within a business.?

For example, if a consumer replies "STOP" or other reasonable word or phrase to an informational text message, a business must stop all informational and commercial calls, texts, emails and other communications to that consumer, regardless of the medium used to communicate the revocation.

To stay compliant, businesses should:

• Implement systems that automatically track and honor opt-out requests.
• Update call center scripts and train agents to recognize all forms of revocation.
• Ensure CRM systems can process requests efficiently across all communication channels.

The 10-day rule: acting quickly

Another major shift in the new regulations is the requirement to process opt-out requests within 10 business days. Companies that fail to comply could face significant penalties, making it essential to streamline revocation processes.

This is not just a technology challenge—it’s also a cultural shift. Sales and marketing teams must embrace compliance as an integral part of their strategy rather than an obstacle.

Balancing compliance with engagement

While compliance is non-negotiable, businesses still need to engage potential customers effectively. Here’s how:

• Ensure explicit, well-documented consent from the outset.
• Rely on first-party data and transparent opt-in mechanisms to improve lead quality.
• Use a one-time confirmation text to verify opt-outs—while respecting revocation requests even if the consumer doesn’t respond. This must be sent within five minutes of the opt-out request.

Leveraging technology for compliance

Technology will play a critical role in adapting to the new TCPA rules. Companies should evaluate their dialers, CRM systems, and compliance tools to ensure they can:

• Handle real-time opt-outs and automate suppression of revoked contacts.
• Be sure data systems communicate with one another to identify and act on revocation requests.
• Integrate AI-driven compliance monitoring to flag potential risks before violations occur.

Compliance action summary

• Review Your Opt Out Process: Ensure your process for adding consumers to your internal DNC list is updated, and applies across communication methods (calls, emails and texts). Communicate with any team doing outreach, including marketing and informational outreach. All businesses that communicate with consumers are responsible for complying with these new opt out rules.
• Include Clear Opt-Out Methods: Because consumers can opt out using any reasonable communication, ensure you have clear opt-out instructions in your communications (e.g.,“Reply ‘STOP’ to opt out.”) However, you must still honor other reasonable opt-out requests, such as “please remove” or even more impolite replies.
• Set Up a Clarification Message: Businesses have five minutes to respond to consumers to ask if they intend to revoke their consent for all messages, or just certain messages.
• Consult with Legal Counsel: Consider a compliance audit and identify potential risks. Review specifically how your operation is prepared for the Consent Revocation Ruling.
• Stay Informed: Keep up-to-date with regulatory changes and subscribe to our monthly Compliance Newsletter

6 Response Tactics for Sales and Lead Generation Operations

Our associates at Troutman Amin, LLP have assembled these helpful tips to help you adapt.

1. Identify and prioritize high value messaging while removing campaigns that tend to draw higher opt-out rates to develop an outreach strategy that maximizes contact rates.
2. For larger organizations, assign a point person to oversee contact strategy and evaluate enterprise needs in light of these new rules.
3. Build out robust opportunities for consumers to provide new consents as you interact and provide services to existing customers.
4. Leverage vendors that offer solutions to identify free form text responses (merely obeying a handful of keywords will not be sufficient).
5. Work on drafting brilliant clarification messages to keep consumers enrolled in messages they desire.
6. Collapse contacts to fewer outbound channels to make it easier to track and honor revocations, and critical re-consents.

Compliance as Business Strategy?

Beyond avoiding fines, businesses that proactively adjust to these new regulations will be better positioned to build consumer trust and enhance brand credibility. Compliance should not be seen as a burden – it’s an opportunity. Companies that respect consumer preferences and implement transparent communication strategies will likely see higher engagement and conversion rates in the long run.

Now is the time to act. Refining consent management practices, updating internal processes, and investing in the right technology will ensure that by April 11, 2025, your business is compliant, consumer-friendly, and prepared for long-term success.

Learn more about Convoso's suite of compliance tools.

DISCLAIMER: The information on this page, and related links, is provided for general education purposes only and is not legal advice. Convoso does not guarantee the accuracy or appropriateness of this information to your situation. You are solely responsible for using Convoso’s services in a legally compliant way and should consult your legal counsel for compliance advice. Any quotes are solely the views of the quoted person and do not necessarily reflect the views or opinions of Convoso.

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