STOP requests and revoking consent: what counts, and what ACR does
What counts as an opt-out under the federal rule today?
The rule is 47 CFR 64.1200(a)(10). As it reads on 7 November 2026, a person can revoke consent, written consent included, by “any reasonable method”. Three methods are reasonable on their face: an automated voice or key-press opt-out on a call; a reply to a text saying stop, quit, end, revoke, opt out, cancel or unsubscribe; and a website or phone number the caller set up for opt-outs.
Other words count as well. If a reply uses different wording, the sender must treat it as a revocation when a reasonable person would read it as one. Requests must be honored within a reasonable time of no more than ten business days, and the caller may not insist on one exclusive way to opt out. Under (a)(11), a request made some other way, such as a voicemail or an email, creates a rebuttable presumption that consent was revoked.
These provisions took effect on 11 April 2025. One piece, which would make an opt-out from one kind of informational message cover unrelated messages from the same caller, was put on hold by waivers until 31 January 2027 (DA 26-12).
What changes on 25 November 2026?
The FCC adopted a new order, FCC 26-67, on 30 September 2026. It was published in the Federal Register on 26 October and takes effect on 25 November. The rewritten (a)(10):
- lets a caller name one or more of the three methods above as the exclusive way to opt out, as long as it discloses that method clearly on the call or in the text;
- lets a texter meet that disclosure by including one of the standard words in each message, while it still honors all seven;
- keeps the any-reasonable-means duty for callers that do not name an exclusive method;
- lets callers treat an opt-out from an informational message as covering only that category, while an opt-out from a marketing call or text ends all marketing calls and texts from that caller.
The order says this replaces the delayed January 2027 date for the revoke-all piece. ACR does not name an exclusive method. It keeps reading plain-language requests, and one opt-out ends every channel from your store, which matches what the new rule expects after an opt-out from a marketing message.
Which words does ACR act on?
Every incoming text is checked for a keyword before anything else reads it. A message made up of one of these words, ignoring case and punctuation, is an opt-out: STOP, STOP ALL, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, REVOKE, OPT OUT, OPTOUT and REMOVE.
The effect is broad. ACR puts the phone number on your store’s suppression list for every channel, adds the shopper’s email address too if it has one, records an opt-out for calls, texts and email, ends the shopper’s runs and marks them as having asked not to be contacted. A number that texts STOP without matching any shopper still goes on the list. The messaging provider sends the standard confirmation for these words.
What about a reply like “please stop texting me”?
A longer reply that plainly asks to stop gets the same treatment as STOP. ACR looks for wording such as “don’t text me”, “never call this number”, “remove me”, “opt me out” or “leave me alone”, then sends one reply: “You won’t get any more texts from us.”
Replies that reach the agent are also read for what the shopper means. If the agent reads a text or email reply as a request not to be contacted, the result is the same.
What do HELP and START do?
HELP or INFO, sent on its own, gets a reply with your store’s name and, if you set one, its support email. START, UNSTOP or SUBSCRIBE undoes a STOP for texts: ACR removes the suppression the STOP keyword created and records SMS consent from that reply, so a later campaign can text the shopper again. It does not restart a run the STOP ended. Calls and email stay off, because those opt-outs were recorded separately.
What if the shopper says it during a call?
When a shopper asks on a call not to be contacted again, the agent uses its do-not-contact tool, and the effect matches STOP: every channel suppressed, the opt-out recorded, the runs ended. In a test run nothing is written, so testing a campaign on your own phone does not suppress you.
And the unsubscribe link in an email?
The link suppresses that email address for email and records an email opt-out. Calls and texts can continue if the shopper consented to them, since the request was about email. A reply asking for no contact at all stops everything, as above. The email rules themselves are in our post on email consent.
What is on the suppression list, and what does it cover?
The list belongs to your store. Entries come from STOP replies, do-not-contact requests by text, email or call, email hard bounces, a carrier report that a number has opted out of texts or cannot receive them, and numbers or addresses your team adds by hand. Each entry covers one channel or all of them: a phone entry for all channels blocks calls and texts, and an email entry blocks email.
ACR checks the list when a shopper would enter a campaign and again before every step, retries included. A request therefore takes effect before the next step goes out. The SMS page and our SMS terms cover the shopper’s side, and compliance lists the defaults.
This describes the FCC rule and ACR’s handling as of 7 November 2026, including a change dated later that month. Nothing here is legal advice for your business.
Sources
- 47 CFR 64.1200(a)(10) to (a)(12), text in force on 7 November 2026 (Cornell LII)
- FCC 26-67, Report and Order and Further Notice of Proposed Rulemaking (adopted 30 September 2026, released 1 October 2026)
- Federal Register, Enhancing the Ability of Consumers To Control the Robocalls, 91 FR 67214 (26 October 2026), effective 25 November 2026
- FCC DA 26-12, Order extending the revoke-all waiver to 31 January 2027 (6 January 2026)
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