What the FCC’s New TCPA Opt-Out Rules Mean for Utilities and Billers

On September 30, 2026, the Federal Communications Commission (FCC) unanimously adopted new rules under the Telephone Consumer Protection Act (TCPA) that change how customers opt out of automated calls and texts. If you send outage alerts, payment reminders, disconnect notices, or other account messages, the changes give you more control over how opt-outs are applied. 

It helps to know where the rules started. In February 2024, the FCC adopted a “revoke all” rule that would have treated an opt-out from one type of message as an opt-out from every message requiring consent from the same entity. The same order also required businesses to honor opt-outs made by any reasonable method, and that part took effect in April 2025. The revoke-all piece never did. The FCC delayed it until April 11, 2026, then again to January 31, 2027, while it reconsidered.

The new order replaces revoke-all with category-level opt-outs for informational messages. The “any reasonable means” standard still applies, unless you designate an exclusive opt-out method, which the new order now allows.

At a glance

• Opt-outs can now be limited to a category. A customer who stops payment reminders doesn’t have to lose outage alerts. Using this is optional.
• You can designate how customers opt out. Pick one or more of three approved methods and disclose it in every call or text.
• Marketing is different. Opting out of promotional messages still ends all promotional messages from you.
• The FCC says the order adds no new compliance obligations. It’s a set of options, and you choose which to use.
• More changes are proposed. They include a shorter processing deadline and mandatory two-way texting, but neither is a rule yet.
• Timing is close. The new rules take effect 30 days after publication in the Federal Register.

Why this matters for utilities and billers

Your customers get a lot of automated messages from you, and most of them are messages customers want. The FCC recognized this, noting that opt-out rules shouldn’t cut people off from information like power outage notices. Utilities, banks, and consumer groups all asked the FCC to rethink the earlier approach.

Getting opt-outs wrong is costly. TCPA violations carry damages of $500 per call or text, and up to three times that for knowing or willful violations, and plaintiffs often sue as a class.

1. Opt-outs can apply to one category

Under the old revoke-all approach, a customer who opted out of payment reminders could also be treated as opting out of fraud alerts, authentication codes, appointment reminders, and utility outage notices. The FCC concluded that this approach didn’t match what customers actually intended, and that many customers wouldn’t realize they’d opted out of everything.

Now you may treat an opt-out from an informational message as applying only to that category. The rule says “may,” so if you’d rather apply opt-outs across all your programs, you can.

The FCC doesn’t define “category.” It names payment reminders, fraud alerts, multi-factor authentication, appointment reminders, and utility outage notices as examples. Since there’s no formal definition, you’ll want to define and document your own categories in a way that reflects what a customer would reasonably expect to stop.

2. Marketing opt-outs still stop all promotional messages

If a customer opts out of a message that contains an advertisement, or is telemarketing, that opt-out covers all future advertising and telemarketing from you, along with affiliates the customer would reasonably expect to be included. The FCC treats a message as informational only if it contains no advertising, so a bill reminder that includes a promotional offer may fall on the marketing side. Keeping service messages and promotions separate makes your category lines cleaner.

3. You can designate how customers opt out

You may choose one or more of these three methods as the only way customers can opt out:

• An automated voice or keypress option during a call
• A reply text using an FCC-standardized word: stop, quit, end, revoke, opt out, cancel, or unsubscribe
• A website or phone number you designate for opt-outs

If you designate an opt-out method, you must clearly and conspicuously disclose it in each call or text. You then don’t have to process opt-outs sent through other channels. Early legal analyses of the order report that a text disclosure can name a single keyword (for example, “Reply STOP to opt out”), as long as your systems still honor all seven standard words. 

If you don’t designate a method, you have to honor opt-outs sent in any reasonable way. If a customer can show they asked to stop, the law assumes consent was revoked unless you can prove otherwise. 

4. Banks get more room for fraud alerts

Financial institutions can now send fraud and data-breach alerts (those that don’t require prior consent) to wireless numbers from “defined sources,” such as an authorized family member on the account, a number captured when the customer calls, or records from another financial institution. The FCC encourages checking the Reassigned Numbers Database, and the existing limit of three messages per event over three days still applies. The FCC declined to extend this to other businesses, so most utilities and billers aren’t covered.

What stays the same

• You still have up to 10 business days to honor an opt-out.
• If you don’t designate an exclusive method, “any reasonable means” still applies.
• Calls using an artificial or prerecorded voice that are exempt or involve marketing must still offer an automated voice or keypress opt-out.
• Text senders who can’t receive replies must still disclose that and offer another way to opt out.

What’s still proposed

The FCC also asked for public comment on these changes. None are rules yet. Comments are due 30 days after Federal Register publication, with replies due 60 days after. 

• Shortening the 10-business-day deadline, with seven suggested
• Requiring two-way texting so customers can opt out by replying
• Allowing category-level opt-outs only if you also offer a one-step “revoke all” option
• Limiting an opt-out to the phone number that received the message, not every number on an account (a request raised by the Edison Electric Institute)
• Clarifying how opt-outs apply across affiliates and separate business divisions
• Shortening the list of standard opt-out words and changing how non-designated methods are evaluated

When it takes effect

The new rules take effect 30 days after publication in the Federal Register, and they replace the January 31, 2027 date that applied to the old revoke-all rule. As of this writing, publication hasn’t been reported, and the FCC will announce the exact date in a public notice.

What to do now

1. Decide whether to use category-level opt-outs, and write down your categories (for example, outage alerts, payment reminders, disconnect notices, and account security).
2. Separate service messages from promotions. Review templates for offers or other promotional content in messages you want treated as informational.
3. Decide whether to designate an exclusive opt-out method, and plan where the disclosure goes in each call and text.
4. Confirm that your systems honor all seven standard text keywords, even if you only display one.
5. Check that opt-outs are processed within 10 business days.
6. Talk to your vendors now. Your messaging platform needs to support category-level suppression and exclusive-method disclosures.
7. Review your approach with legal counsel.

How KUBRA can help with Notifi

Notifi is KUBRA’s preference management and omni-channel communications solution, covering text, automated voice, email, and mobile push. It tracks customer preferences and automates delivery based on those preferences and your business rules, helps capture consent, gives customers a way to unsubscribe, and includes a template editor with a preview before changes go live.

Here’s how Notifi helps with the new rules:

• Categories: Tracking preferences by message type is what category-level opt-outs depend on.
• Disclosures: The template editor makes it easier to add your opt-out instructions to every message.
• Opt-out methods: Two-way text and automated voice channels support the reply-text and keypress methods the FCC lists.

A note for KUBRA clients: KUBRA’s compliance and product teams are monitoring this rulemaking and will contact clients directly if anything requires a change on your end. If you have questions about how this applies to your own programs, reach out to your KUBRA account team.

Read the order

The full text is available from the FCC: Report and Order and Further Notice of Proposed Rulemaking, FCC 26-67 (CG Docket No. 02-278)

LEGAL DISCLAIMER: This post is for general informational purposes only and is not legal advice. The contents of this post may not reflect the most current legal developments and any rules discussed may vary depending on your jurisdiction. Please seek independent legal advice from your legal counsel about how these rules may apply to your organization.