TCPA 2026 compliance for call centers

TCPA class actions spiked 283% in September 2025. The FCC rewrote how consent revocation works. Texas passed a mini-TCPA that covers text messages. And the blanket revocation rule takes effect April 2026. This is what changed, what's coming, and how to configure your dialer so you don't become the next seven-figure settlement. --- I've been building and maintaining call center infrastructure for over a decade. I've watched the TCPA go from a statute most operators barely thought about to the single biggest litigation risk in the outbound industry. And the 2025-2026 cycle has been the most chaotic regulatory stretch I've seen. Between January 2025 and March 2026, we got: a major FCC consent rule vacated by a federal court, a new revocation framework that went live, a blanket revocation rule that's about to go live, three new state mini-TCPAs, and an FCC Notice of Proposed Rulemaking that could rewrite the abandonment rules entirely. Oh, and TCPA lawsuit filings hit all-time highs. If you run outbound campaigns on VICIdial or any predictive dialer, this post walks through every change that matters, what the actual compliance requirements are right now, and the specific configurations that keep your operation out of the crosshairs. For the detailed VICIdial settings guide, see our TCPA compliance checklist. For timezone-specific dialing configuration, see timezone dialing and TCPA safe hours. --- ## The 2025-2026 TCPA Timeline: What Happened The chronological sequence matters because the order of events created a situation where many operators either over-corrected or under-corrected depending on when they last checked the rules. ### January 2025: One-to-One Consent Rule -- Vacated In December 2023, the FCC adopted the "one-to-one consent" rule to close what it called the "lead generator loophole." The rule would have required that consumer consent to receive autodialed or prerecorded calls be given to one specific seller at a time. No more comparison-shopping forms where a single checkbox authorizes calls from 10 different companies. The rule was set to take effect January 27, 2025. On January 24, the FCC issued an order postponing the effective date to January 26, 2026. But the same day, the U.S. Court of Appeals for the Eleventh Circuit vacated the rule entirely in Insurance Marketing Coalition v. FCC, finding the FCC exceeded its statutory authority. The court reasoned that "prior express consent" under the TCPA has a plain meaning -- clearly stating willingness to receive calls -- and the FCC can't redefine it to require one-to-one specificity. In April 2025, the FCC confirmed it would not challenge the ruling. In September 2025, the FCC issued a final rule formally eliminating the one-to-one consent requirement. What this means for you right now: The one-to-one consent rule is dead. Multi-seller lead forms are still legally valid under federal law. A consumer who fills out a form authorizing calls from "Company A and its partners" has given valid prior express consent to all named parties. The catch: Just because the federal rule died doesn't mean you should be sloppy about consent. Several states have their own consent requirements that are stricter than the federal baseline. And plaintiff attorneys don't need the one-to-one rule to sue you -- they'll argue the consent language was too vague, the form was misleading, or the consumer didn't see the disclosure. Keep your consent records tight regardless. ### April 2025: Consent Revocation Rules -- Partially Live This is the change that went into effect and matters the most right now. Effective April 11, 2025, the FCC's new revocation rules established that consumers can revoke consent to receive calls through any reasonable means. Not just the specific method your company designates. Any reasonable method. The FCC specified these keywords as automatic revocation triggers: stop, quit, revoke, opt out, cancel, unsubscribe, end. But those aren't the only valid revocations. A consumer saying "take me off your list," "don't call me again," or "I don't want these calls" on a live call with your agent -- all valid. Additionally, revocations made through any interactive keypress mechanism on an automated call, or through a website or phone number provided by the business, are valid. The 10-business-day window: Once a consumer revokes consent, you have a "reasonable time" to process it. The FCC has indicated this means no more than 10 business days. Most plaintiff attorneys argue 24-48 hours is "reasonable." If you want to stay safe, process revocations within 24 hours. What went into effect April 2025: - "Any reasonable means" standard for revocation - Mandatory honoring of the seven standard keywords - 10-business-day processing window What got delayed to April 2026: - The "blanket revocation" rule -- where a consumer opting out of one type of message from your company is treated as opting out of ALL types of messages from you. The FCC granted a limited waiver pushing this to April 11, 2026. That April 2026 blanket revocation deadline is 16 days away as of this writing. More on that below. ### September 2025: Texas Mini-TCPA Expansion Effective September 1, 2025, Texas Senate Bill 140 materially expanded the Texas Business and Commerce Code. The changes: - Text messages now covered: The definition of "telephone solicitation" now includes text messages, graphic messages, and image transmissions. Before SB 140, the Texas mini-TCPA only covered voice calls. - Registration required: Sellers making telephone solicitations from or into Texas must obtain a registration certificate for each physical location. - Enhanced penalties: Violations are now expressly deemed "unfair and deceptive practices" under Texas law, carrying $500-$1,500 per unlawful call or text. The AG can seek up to $5,000 per violation. - Stronger private right of action: Plaintiffs face fewer procedural barriers under the Deceptive Trade Practices Act (DTPA) for violations. If you send text campaigns into Texas from your dialer or any integrated SMS platform, you need to register and comply with SB 140 or you're exposed. ### October 2025: FCC Proposes Major NPRM On October 28, 2025, the FCC unanimously adopted a Further Notice of Proposed Rulemaking (FNPRM) that could reshape TCPA compliance. Comments were due January 5, 2026; reply comments due February 3, 2026. The proposals include: Possible elimination of abandonment rules: The FCC is considering removing the rules that require 15-second ring time before disconnect and the 3% abandon rate safe harbor for predictive dialers. The logic is that dialer technology has improved enough that these rules may be unnecessary. This is not yet law -- it's a proposal. But if adopted, it would completely change how predictive dialers are regulated. Consent revocation refinements: The FCC is reconsidering the "revoke-all" rule (the blanket revocation set for April 2026). They're asking whether it "unduly restricts consumers' ability to receive wanted calls" -- like pharmacy reminders, bank alerts, or appointment notifications from businesses with multiple service lines. DNC rule changes: An early draft proposed eliminating company-specific DNC list requirements. The final NPRM text removed that proposal -- internal DNC rules remain in effect. But the FCC did propose deleting certain company-specific DNC provisions where they believe general anti-robocall rules already cover the same ground. Caller ID and call branding: The FCC proposed requiring that whenever a terminating provider displays A-level STIR/SHAKEN attestation, it must also show the caller's verified name. This would make anonymous robocalling significantly harder. Status as of March 2026: The comment period has closed. No final rule has been adopted yet. Plan for the current rules, not the proposed ones. --- ## The Blanket Revocation Deadline: April 11, 2026 This deserves its own section because it's imminent and a lot of operators don't fully grasp the implications. Starting April 11, 2026, if a consumer revokes consent for one type of communication from your company, that revocation applies to all communications from you -- even unrelated ones. Example: A consumer receives a marketing text from your solar campaign and replies "STOP." Under the current rules (through April 10), that revocation only applies to the solar marketing texts. Under the blanket rule (starting April 11), that "STOP" means you can't call them about home warranties, insurance, or anything else either. One opt-out kills all channels and all campaigns from your organization. The FCC's October 2025 NPRM floated the idea of narrowing or eliminating this rule, recognizing it could prevent consumers from receiving wanted calls (appointment reminders, fraud alerts, etc.). But as of this writing, no modification has been adopted. The April 11 deadline stands. ### What you need to do before April 11: 1. Unify your opt-out processing across all campaigns. If a consumer opts out anywhere -- any campaign, any channel -- that phone number needs to land on a system-wide DNC list, not just a campaign-specific one. 2. In VICIdial: Use the Internal DNC list (Admin > DNC Lists > Internal DNC), not just campaign-specific DNC lists. When a consumer revokes consent, add the number to the system-wide internal DNC so it blocks across all campaigns. 3. Audit your multi-campaign operations. If you run separate campaigns for different products under the same legal entity, all of them need to respect a single unified opt-out list after April 11. 4. Document everything. When the blanket revocation rule takes effect, plaintiff attorneys will look for companies that honored an opt-out on Campaign A but continued dialing the same number on Campaign B. That's an easy lawsuit. --- ## State Mini-TCPAs: The Patchwork That Multiplies Your Risk Federal TCPA compliance is the floor. State laws are often the ceiling. And in 2025-2026, more states tightened their telemarketing rules. Below is the current landscape for the states that matter most. ### Florida (FTSA -- Florida Telephone Solicitation Act) Florida's mini-TCPA has been in effect since July 2021, with 2023 amendments clarifying ATDS definitions. Key requirements: - Calling hours: 8:00 AM to 8:00 PM local time (one hour shorter than federal) - Contact limit: Maximum 3 attempts per recipient per 24-hour rolling period (calls + texts combined) - Consent: Prior express written consent required for automated calls and texts - ATDS definition: After 2023 amendments, ATDS means systems that randomly or sequentially generate numbers -- pre-existing contact lists are excluded - Penalties: $500 per violation, $1,500 for willful violations - Private right of action: Yes, and it's being used aggressively. A South Florida firm filed over 100 TCPA/FTSA timing-violation lawsuits in March 2025 alone. VICIdial configuration for Florida: Set a state_call_time entry for Florida with an 8:00 PM cutoff. Set contact attempt limits using VICIdial's list management and lead recycling rules -- configure Dial Timeout and Daily Call Count Limit to cap at 3 attempts per 24 hours for Florida leads. ### Oklahoma (OTSA -- Oklahoma Telephone Solicitation Act) Oklahoma's mini-TCPA has been in effect since November 2022. It's one of the most aggressive state telemarketing laws in the country: - Calling hours: 8:00 AM to 8:00 PM local time - Contact limit: Maximum 3 calls per 24-hour period to the same person regarding the same subject - Caller ID: Must transmit originating phone number and name (if CNAM supported by carrier) - Consent: Prior express written consent required for automated commercial calls and texts - ATDS definition: Broad -- covers any automated system for selecting/dialing numbers or playing recorded messages - Penalties: $500 per violation, $1,500 for willful/knowing violations VICIdial configuration for Oklahoma: Same approach as Florida -- state_call_time with 8 PM cutoff, daily call count limits at 3. Verify your CID groups are transmitting real numbers with proper CNAM. ### Texas (Expanded September 2025) As covered above, SB 140 expanded coverage to text messages, added registration requirements, and increased penalties. The key operational impact: - Registration: Required for each physical location making solicitations from or into Texas - Text messages now regulated: If you're running SMS campaigns alongside your dialer, texts to Texas numbers fall under the mini-TCPA - Penalties: $500-$1,500 per call/text, plus AG enforcement up to $5,000 per violation - Sunday restriction: No telemarketing calls before noon on Sundays VICIdial configuration for Texas: Add a state_call_time for Texas with Sunday hours starting at 12:00 PM. Register with the Texas

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