SMS Compliance
SMS and AI Calling Compliance Tracker
Most guidance on this subject is stale the month after it is published. This page exists to be the one that is not.
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Published
Upcoming deadlines
| Date | What happens | Who it affects |
|---|---|---|
| 1 Oct 2026 | Verizon outbound A2P pass-through fee rises from $0.0045 to $0.005 per message, across 10DLC, short code and toll-free. | Anyone sending at volume. Material on large sends, negligible on small ones. |
| 31 Jan 2027 | The revoke-all provision at 47 CFR 64.1200(a)(10) takes effect after repeated delays. One revocation will apply to all future calls and texts from you to that number, including unrelated topics. | Anyone running more than one messaging programme against the same contact list. |
The January 2027 date is the one that requires actual work rather than a budget line. Consent and revocation state has to live on the contact record and be respected by every system that can send. If reactivation runs through a separate blast tool that does not write opt-outs back to the CRM, that is the thing to fix before the deadline, and it is worth fixing anyway.
What is in force now
| Since | Requirement | Detail |
|---|---|---|
| Feb 2024 | AI voices are artificial or prerecorded voice under the TCPA | AI voice calls to mobiles need prior express consent; telemarketing needs prior express written consent. |
| 1 Feb 2025 | Carriers block unregistered 10DLC traffic | 100% blocked, not throttled. See the A2P 10DLC guide. |
| 11 Apr 2025 | Revocation by any reasonable means | Plain-language opt-outs count, not only platform keywords. Honor within ten business days. |
| Ongoing | Prior express written consent, pre-2023 standard | Required for automated marketing texts and calls to mobile numbers. |
Changelog
| Effective | Change | Verified |
|---|---|---|
| 24 Jan 2025 | Eleventh Circuit vacates the FCC one-to-one consent rule in Insurance Marketing Coalition Ltd. v. FCC. FCC does not appeal and later deletes the language. Pre-2023 PEWC governs. | 31 Aug 2026 |
| 7 Apr 2025 | FCC delays the revoke-all portion of the consent order from 11 April 2025 to 11 April 2026. Later extended again. | 31 Aug 2026 |
| 2026 | FCC extends the 64.1200(a)(10) waiver to 31 January 2027. | 31 Aug 2026 |
| 1 Oct 2026 | Verizon A2P pass-through fee increase to $0.005 announced. | 1 Sep 2026 |
Why this page exists
When we checked the TCPA position before publishing our guide on texting old leads, the majority of published material stated that the FCC one-to-one consent rule had taken effect in January 2026. It had been struck down a year earlier.
That is not an unusual failure in this subject area, it is the normal condition. Compliance content gets written once, ranks, and is never revisited, while the underlying rules move continuously through litigation, waivers, and carrier policy. Anyone acting on the stale version either abandons a campaign that is perfectly lawful or assumes a protection that no longer exists.
So this page carries dates on every row, links to primary sources rather than to commentary, and gets reviewed rather than left. If you only take one thing from it: check the date on any compliance article before you act on it, including this one.
Common questions
- What is currently in force for texting US consumers?
- Four things. Prior express written consent under the pre-2023 standard for automated marketing texts to mobiles. Revocation by any reasonable means, honored within ten business days, in force since 11 April 2025. A2P 10DLC brand and campaign registration, enforced by outright carrier blocking since 1 February 2025. And AI-generated voices treated as artificial or prerecorded voice under the TCPA since February 2024.
- What is the next deadline I need to plan for?
- Two. On 1 October 2026 Verizon's A2P pass-through fee rises to $0.005 per message. On 31 January 2027 the revoke-all provision at 47 CFR 64.1200(a)(10) takes effect, after which a single opt-out applies to all of your messaging to that number rather than just the campaign it came from.
- Is the FCC one-to-one consent rule in force?
- No. It was vacated by the Eleventh Circuit on 24 January 2025 and the FCC formally deleted the language in 2025. A large amount of currently published material still states that it took effect, which is wrong. This is the single most repeated error in the SMS marketing literature.
- How often is this page updated?
- Whenever something changes, and the date at the top reflects the last review rather than the last cosmetic edit. Entries carry the date the change took effect and the date we verified it. If an entry looks stale relative to today, treat the primary source link as authoritative over this page.
Sources
- 1.Insurance Marketing Coalition Ltd. v. FCC, No. 24-10277 (11th Cir. 24 January 2025)
- 2.FCC final rule eliminating the one-to-one consent requirement
- 3.FCC: TCPA rules on revoking consent for robocalls and robotexts
- 4.FCC further extends the effective date of the revoke-all rule to 31 January 2027
- 5.A2P carrier fees guide 2026 Verizon increase effective 1 October 2026.
We track this because we have to
Every partner account we run sends SMS, so a rule change is an operational problem for us before it is a content topic. If you want your own consent architecture checked against the January 2027 deadline, that is a concrete piece of work with a clear finish line.
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