--- title: "SMS Consent Before BFCM: What the FCC Changed on 30 September 2026" slug: "fcc-sms-consent-revocation-bfcm" url: "https://joy.so/blog/fcc-sms-consent-revocation-bfcm/" kind: "post" author: "Thomas Nguyen" author_url: "https://joy.so/author/thomas/" published_at: "2026-11-09T09:00:00.000+00:00" updated_at: "2026-11-09T09:00:00.000+00:00" description: "The FCC revised how US consumers revoke consent to texts. What the order says, paragraph by paragraph, before BFCM." category: "Marketing channels" tags: ["Marketing channels", "BFCM & seasonal", "Fraud & compliance", "Loyalty Program"] reading_time: 8 feature_image: "https://cdn-web.joy.so/cdn/image/2026/10/row32-sms-consent-5c2d87.webp" --- # SMS Consent Before BFCM: What the FCC Changed on 30 September 2026 Seven words end a customer's consent to be texted by a business in the United States: stop, quit, end, revoke, opt out, cancel and unsubscribe. The FCC adopted that list in 2024. On 30 September 2026 the Commission changed what a sender is allowed to do around them, eight weeks before Black Friday. What follows is a reading of that order, with paragraph numbers, for merchants who text US customers about sales, points and rewards. It is not legal advice. Where the order leaves a question that only a lawyer can answer, this page says so and stops. **Key Takeaways** - On 30 September 2026 the FCC adopted an order, FCC 26-67, that revises how consumers revoke consent to autodialed calls and texts in the United States. - For marketing texts the order is direct: one revocation request ends consent to all future marketing texts from that sender. - A sender may now designate one method, such as replying with a keyword, as the exclusive way to revoke. The method must be disclosed in each text, and all seven standard keywords must still be honoured. - For informational texts a sender may read a revocation as applying only to the category of message it answered. - The changes take effect 30 days after publication in the Federal Register. On 13 October 2026 that publication had not happened, so the date is not known and may fall in or near BFCM week. **Published 9 November 2026; written 13 October 2026.** United States only. Every statement about the rule is taken from the FCC's own document, FCC 26-67, read on 13 October 2026 and linked. This page is not legal advice and has not been reviewed by a lawyer. Confirm the effective date and how the rule applies to your messages with counsel. ## What the FCC adopted The document is [a Report and Order and Further Notice of Proposed Rulemaking](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) in CG Docket No. 02-278, adopted on 30 September 2026 and released the next day. It covers what the FCC calls robocalls, a term the order defines to include "any call made or text message sent using an automatic telephone dialing system". Paragraph 2 summarises the changes: the Commission modifies its rules "**to allow callers to interpret a revocation request as applying only to the specific category of informational robocalls to which the revocation was directed, to allow callers to designate an exclusive means to revoke consent**", and to adjust an exemption for financial institutions that does not concern retailers. ![Table comparing the FCC's 2024 consent revocation rule with the September 2026 order for marketing texts, informational texts, revocation methods, keywords and timing](https://cdn-web.joy.so/cdn/image/2026/10/fig-row32-changes-c4d420.webp) _The rule before and after. Source: [FCC 26-67](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf)_ | | Under the 2024 rule | Under the September 2026 order | | --- | --- | --- | | Marketing texts | Covered by the same revoke-all provision as every other message | One revocation request ends consent to all marketing from that sender | | Informational texts | A revocation was to apply to all further robocalls and texts from the sender. That part had been waived until 31 January 2027 | May be read as applying only to the category of message it answered | | How a customer may revoke | Any reasonable method | The sender may designate an exclusive method, if it is disclosed in each text | | Keywords | Seven standard words | The same seven. Disclosing one is enough; all seven must be honoured | | Time to honour a request | Ten business days at most | Unchanged. The FCC asks whether to shorten it | ## Marketing texts: one request ends all of them The change that drew attention concerns informational messages, and the order is careful to fence it off: "We emphasize that this specific modification affects only informational robocalls" (paragraph 10). For marketing, [paragraph 14 of the order](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) reads: "**Revocation requests made in response to robocalls that contain an advertisement or constitute telemarketing revoke consent to all future robocalls containing an advertisement or that constitute telemarketing from that caller**". The Commission adds that "consumers need only make a single revocation request". The same paragraph reminds senders that a do-not-call request applies to the entity making the call and to "affiliated entities if the consumer reasonably would expect them to be included". A merchant running several brands from one sending account has a question to take to counsel there. For a loyalty program the open question is classification. A text announcing a sale is plainly marketing. A text saying that an order has shipped is plainly not. A text saying that 400 points are about to expire, with a link to the store, sits somewhere a merchant should not guess at. If such a text is marketing, a customer who replies with a keyword to that one message has ended every marketing text from the brand, in the week the brand most wants to send them. ## A sender may now choose the method Under the 2024 rule a sender had to honour revocation made by any reasonable method. Paragraph 15 changes that: the Commission will "allow callers to designate an exclusive means by which consumers may revoke consent". Three methods qualify: an automated voice or key-press mechanism on a call, a reply to a text using the standard words, or a website or telephone number the sender provides. The condition is disclosure, "so long as the caller clearly and conspicuously discloses the designated method for revoking consent on the call or in the text" (paragraph 16). The Commission declined a request to let senders decide when and how to tell customers. On keywords the order is practical. Commenters pointed out that listing all seven words would use up a text message, and [the Commission agreed in paragraph 17](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf): senders "**can satisfy the disclosure requirement by disclosing even just one of the standardized words in each text message**". The next sentence closes the gap: they "still must honor revocation requests made using any of the standardized words". A sender that designates nothing stays under the older standard. The revised rule says such callers "must process revocation requests made by any reasonable means". ## Informational texts: revocation by category For messages that contain no advertising or telemarketing, the revised rule lets a sender interpret a revocation "as applying only to the specific category of informational robocalls and text messages to which the revocation was directed and not to all communications". The order's examples are fraud alerts, appointment reminders and utility outage notices. The Commission also asks, in the further notice attached to the order, whether senders should be required to offer a single step that revokes everything. That question is open for comment and nothing has been decided. ## The effective date is not known yet [Paragraph 24 of the FCC's order](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) sets the timing: the amendments "**become effective 30 days after Federal Register publication**" and will "supersede the delayed effective date" of the earlier provision, which had been pushed to 31 January 2027. The Commission refused a request to allow up to twelve months. ![Timeline of FCC 26-67 from adoption on 30 September 2026 to an effective date 30 days after Federal Register publication](https://cdn-web.joy.so/cdn/image/2026/10/fig-row32-timeline-ae67b5.webp) _Two dates are fixed and two depend on publication._ On 13 October 2026, when this page was written, the order had not appeared in the Federal Register. No merchant, vendor or law firm controls when it does. Publication in late October would put the effective date in late November. Check the Federal Register entry for CG Docket No. 02-278 before you rely on any date, including the ones in this paragraph. ## What is still out for comment The further notice asks about four things, raised jointly by the American Bankers Association, the National Consumer Law Center and ACA International: the time allowed to honour a request, two-way texting, a required revoke-all method, and how a request applies to affiliates. The first is the one a retailer will feel. The current limit is "a reasonable time not to exceed ten business days from receipt". In [the further notice section of the order](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf), paragraph 30 opens with "We seek comment on whether to reduce the timeframe for callers to honor revocation requests". Ten business days is longer than a BFCM campaign. A platform that takes most of that window to process a stop request is within the rule as it stands and may not be within the next one. ## Where a loyalty program touches this Loyalty apps sit on the consent side of SMS more often than the sending side. Joy, for example, pays points the first time a customer opts in to SMS marketing and records the result in Shopify, so that "whichever tool actually sends your messages reads the same state you rewarded on"; [Joy's guide to its SMS marketing earning program](https://help.joy.so/reward-programs/earning-programs/subscribe-to-sms-marketing/) says the reward has "no claw-back" if the customer unsubscribes later. The background is in our note on [rewarding the SMS opt-in](https://joy.so/updates/sms-marketing-opt-in-rewards/), and the sending side in [Joy's connection to Attentive](https://joy.so/updates/joy-attentive-integration/). That division matters for the questions below. The consent record lives in Shopify, the reward lives in the loyalty app, and the obligation to honour a stop request lands on whoever sends the message. ## When this is not your problem this month If you do not text customers in the United States, none of it applies. If you do, and your SMS platform already treats any of the seven words as a stop for all marketing and processes it at once, the order asks nothing new of you in November. The Commission says as much: "We impose no new compliance obligation" (paragraph 26). ## Questions to put to your SMS vendor and your lawyer - Which of our automated loyalty texts (points earned, points expiring, reward available, tier change) do we treat as marketing, and who decided? - Does our platform recognise all seven standard words, or only STOP? - Have we designated an exclusive revocation method, and does every text disclose it? - How long does a stop request take to reach every list and flow we send from, including flows triggered by the loyalty app? - Does our confirmation text contain anything promotional? The rule permits a confirmation that "does not include any marketing or promotional information". - Has the order been published in the Federal Register, and what is the effective date? The wider order of work for the weeks before the sale is in our [Black Friday checklist](https://joy.so/blog/black-friday-checklist/). ## Test the second word STOP is the word everybody tests. The other six are in the rule too. Send a marketing text to your own phone from the account you will use in BFCM week, reply QUIT, and watch what happens to the next campaign. ## FAQs ### What is FCC 26-67? A Report and Order and Further Notice of Proposed Rulemaking in CG Docket No. 02-278, adopted on 30 September 2026 and released on 1 October 2026. [The order amends the FCC's rule on revoking consent](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) to autodialed calls and texts, 47 CFR 64.1200(a)(10). ### When does it take effect? [The order's paragraph 24](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) says the amendments "become effective 30 days after Federal Register publication". As of 13 October 2026 the order had not been published there. Look up CG Docket No. 02-278 in the Federal Register for the date. ### Does it apply to stores outside the United States? It is a United States rule. If you send texts to US numbers, ask counsel how it reaches you; if you do not, it does not concern your program. ### Is a points-balance text marketing or informational? This page does not answer that, and neither does the order in terms a merchant can apply alone. The rule separates messages that contain an advertisement or constitute telemarketing from those that do not. Which side a given loyalty text falls on is a question for a lawyer who has read the text. ### Do I have to list all seven keywords in every text? No. [The FCC's order says](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf) text senders "can satisfy the disclosure requirement by disclosing even just one of the standardized words in each text message", and that they "still must honor revocation requests made using any of the standardized words". ### Does the order add new obligations? [In the FCC's own words in paragraph 26](https://docs.fcc.gov/public/attachments/FCC-26-67A1.pdf): "We impose no new compliance obligation". It changes what a sender is permitted to do, and it asks for comment on changes that would add obligations later.