# TCPA Compliance in 2026: What the FCC Order Changes

> The 2026 FCC order reshapes TCPA consent, opt-out, and enforcement rules. See how Plura AI helps contact centers implement the right controls.

**Published:** 2026-09-09 | **Updated:** 2026-11-10 | **Author:** plurasync
**URL:** https://www.plura.ai/articles/how-to-ensure-tcpa-compliance
**Type:** post

**Categories:** AI Contact Centers

![TCPA Compliance in 2026: What the FCC Order Changes](https://plura.sites.aigrowthagent.co/wp-content/uploads/sites/75/2026/09/1788867967066-88e6fa8b213d-1024x572.webp)

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## Content

*Written by: Matt Beucler, CEO, Plura AI | Last updated: November 9, 2026*

*Updated November 2026*

## Key Takeaways

- The FCC’s October 26, 2026 order (FCC 26-67) introduces category-specific revocation for informational robocalls and exclusive revocation methods, both effective November 25, 2026.
- Consent must be captured as immutable, timestamped evidence with source URL, IP address, disclosure language, and affirmative action for every contact.
- Revocation requests must propagate across all channels and vendors within 10 business days, with category-level suppression logic required for informational calls.
- Pre-dial DNC scrubbing, quiet-hours enforcement, and STIR/SHAKEN authentication are mandatory compliance surfaces that must be enforced before any call leaves the network.
- Plura AI provides the enforcement layer that operationalizes TCPA compliance inside the dial path for high-volume voice, SMS, and RCS operations.

[See how Plura AI enforces TCPA compliance](https://www.plura.ai/plura-webchat?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent)

## What Changed in 2026: The October 26 FCC Order and the November 25 Effective Date

The FCC’s final rule “Enhancing the Ability of Consumers To Control the Robocalls” (FCC 26-67, CG Docket No. 02-278) was adopted September 30, 2026 and released October 1, 2026.2 It was published in the Federal Register on October 26, 2026 at 91 FR 67214 and takes effect November 25, 2026, superseding the previously extended January 31, 2027 effective date for the relevant portion of 47 CFR § 64.1200(a)(10). Three changes define the operative compliance surface as of November 25, 2026.

**1. Category-specific revocation for informational robocalls.** For informational robocalls and robotexts containing no advertising or telemarketing, a caller may treat a revocation request as applying only to the specific category of informational calls or texts to which the request was directed. The FCC noted that under the prior “revoke all” interpretation, a consumer who revoked consent in response to payment reminders also stopped unrelated fraud alerts, multi-factor authentication messages, appointment reminders, and utility outage calls, which the record indicated often conflicted with consumer intent. This rule does not change advertising or telemarketing: a revocation made in response to a promotional or telemarketing message revokes consent for all future advertising and telemarketing communications from that caller.

**2. Exclusive revocation methods.** Callers may designate one of three methods under 47 CFR § 64.1200(a)(10) as exclusive: an automated interactive voice or key-press opt-out mechanism, specific standardized words in reply to a text, or a caller-provided website or telephone number. The designated method must be clearly and conspicuously disclosed on the call or in the text. Callers that do not designate an exclusive method must continue honoring revocation by any reasonable method. For text senders designating reply text as the exclusive method, disclosing even one standardized word (for example, “STOP”) satisfies the disclosure requirement, but senders must still [honor revocations made using any of the standardized words: stop, quit, end, revoke, opt out, cancel, or unsubscribe](https://hunton.com/insights/publications/how-fcc-robocall-rules-reshape-tcpa-opt-out-compliance).

**3. One-to-one consent status.** The Eleventh Circuit vacated the FCC’s one-to-one consent rule in January 2025, and the FCC formally repealed it in July 2025. The [pre-2023 written-consent standard applies to marketing calls and texts to cell phones made with an autodialer or recorded/AI-generated voice](https://telemarketing.com/blog/tcpa-penalties-and-enforcement) under 47 CFR § 64.1200, as confirmed by the Congressional Research Service report R48941 (May 12, 2026).

A companion Further Notice of Proposed Rulemaking was published the same day at 91 FR 67239, with comments due November 25, 2026 and reply comments due December 28, 2026. That document is proposed, not controlling. It seeks comment on shortening the 10-business-day revocation window (potentially to seven business days) and on a “revoke all” mechanism. Compliance programs should flag it as a pending change, not an operative rule.

Direct readers to the regulation text and qualified counsel for interpretation of what these changes describe for their specific operations. See also Plura’s [TCPA Consent Requirements guide](https://www.plura.ai/articles/tcpa-consent-requirements-2026/?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) for a deeper treatment of the consent framework. Those changes sit on top of a consent framework that has not moved: the consent level still depends on the channel and the technology.

## Consent by Communication Type: Practical Consent and Evidence Mapping

Consent level is set by the channel and the technology, not by the campaign’s intent. The list below shows which consent category each communication type falls under and which artifact supports it, drawn from 47 CFR § 64.1200(a)(1)-(3). Consult qualified counsel to determine which category applies to a specific campaign.

- **Manual informational call** (live agent, no autodialer, no recorded voice): no TCPA autodialer or prerecorded-voice consent requirement, but DNC and calling-window rules still apply. Artifact: DNC scrub record with date, internal suppression check, and call timestamp in local time.
- **Automated informational call or text** (autodialer or AI/prerecorded voice, no advertising): prior express consent under 47 CFR § 64.1200(a)(1), with category-specific revocation applying from November 25, 2026. Artifact: consent timestamp, source URL, IP address, exact disclosure language, affirmative action, call category label, and revocation events with method and timestamp.
- **Automated marketing call or text** (autodialer or AI/prerecorded voice, advertising or telemarketing content): prior express written consent under 47 CFR § 64.1200(a)(2)-(3), with a single revocation ending all marketing from that caller. Artifact: signed or recorded written consent with specific number named, exact disclosure language, source URL, IP, timestamp, affirmative action, and suppression propagation status across all channels.
- **Prerecorded telemarketing to a residential line**: prior express written consent under 47 CFR § 64.1200(a)(3), with no advertising or telemarketing exemption. Artifact: written consent record with all fields above plus campaign ID, DNC scrub date, quiet-hours enforcement log, and abandoned-call rate documentation per 47 CFR § 64.1200(a)(7)(iii).

Every item in this list functions as an engineering spec. The artifact is the timestamped, source-linked, IP-tagged record a compliance owner can produce in discovery or a regulatory inquiry. For a full treatment of consent requirements, see Plura’s [TCPA Consent Requirements guide](https://www.plura.ai/articles/tcpa-consent-requirements-2026/?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent).

## The Consent Ledger as System of Record

A defensible consent ledger is an engineering requirement and a daily operations tool. It must be immutable, timestamped, per-contact, and exportable. The fields it captures for each contact record:

- Contact identifier (phone number, email, or account ID)
- Consent level (express, express written, or exemption basis)
- Exact disclosure language shown at the point of consent capture
- Source URL where consent was captured
- IP address of the consenting device
- Timestamp of the consent event
- Affirmative action taken (checkbox, signature, key-press, verbal confirmation)
- Campaign ID and call or text category
- Revocation events: method used, timestamp, and category targeted
- Suppression propagation status across all channels and vendors

Operational ownership splits three ways because no single team can hold all of it: the compliance owner sets policy, engineering guarantees ledger integrity, and legal sets retention policy. The [recordkeeping baseline under 16 CFR § 310.5 requires records supporting Telemarketing Sales Rule (TSR) compliance to be kept for 24 months](https://biglysales.com/tcpa-state-guide). Consent records that cannot be produced on demand represent a gap in the audit trail.

## Opt-Out and Revocation Handling Across Channels

The revocation changes above run on top of a deadline that did not change. Under [47 CFR § 64.1200(a)(10), all revocation requests must be honored within a reasonable time not to exceed 10 business days from receipt](https://hunton.com/insights/publications/how-fcc-robocall-rules-reshape-tcpa-opt-out-compliance).2 The standardized opt-out words for text channels are: stop, quit, end, revoke, opt out, cancel, and unsubscribe. Callers that have not designated an exclusive revocation method must honor revocation by any reasonable means, a standard courts have applied broadly.

The November 25, 2026 change adds a suppression-logic requirement that most platforms are not built to handle. Category-specific revocation for informational robocalls means the suppression system must identify which call category an opt-out targets and honor it without suppressing other wanted informational calls. A payment-reminder opt-out stops payment reminders, while fraud alerts or appointment reminders can continue if those categories contain no advertising. A marketing opt-out still ends all marketing from that seller across every channel.

Cross-platform suppression sync is the operational gap that creates the most exposure. A revocation received via SMS must propagate to the voice dialer, the RCS (Rich Communication Services) platform, and every vendor running campaigns on the seller’s behalf, within the 10-business-day ceiling. The pending FNPRM described above could shorten that window, so design programs to honor revocations faster than the current ceiling. For a detailed treatment of DNC list obligations, see Plura’s [TCPA DNC Requirements guide](https://www.plura.ai/articles/tcpa-dnc-requirements-2026/?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent).

## DNC and Quiet-Hours Enforcement Before the Dial

The FTC’s TSR at 16 CFR Part 310 requires scrubbing against a version of the National Do Not Call Registry obtained no more than 31 days before any call is made. The federal calling window is 8:00 a.m. to 9:00 p.m. in the called party’s local time. [Company-specific do-not-call requests must be honored for five years](https://biglysales.com/tcpa-state-guide). These rules set the floor for enforcement.

State overlays impose stricter rules in many jurisdictions. Representative examples, each of which should be verified against current statute and qualified counsel:

- **Oklahoma** (15 O.S. §§ 775C.1-775C.6): [8 a.m. to 8 p.m. window](https://biglysales.com/tcpa-state-guide); [cap of three calls per 24 hours on the same subject matter regardless of which number is used](https://biglysales.com/tcpa-state-guide).
- **Washington** (RCW 80.36.400): [flat prohibition on using an automatic dialing and announcing device for commercial solicitation, with no prior express written consent exception in the statute](https://biglysales.com/tcpa-state-guide).
- **Pennsylvania** (Act 47 of 2026, 73 P.S. § 2245): [9 a.m. to 7 p.m. window](https://biglysales.com/tcpa-state-guide); [no Sunday or holiday calls](https://biglysales.com/tcpa-state-guide).
- **Maryland** (Md. Code, Com. Law §§ 14-4501 to 14-4503): [8 a.m. to 8 p.m. window](https://biglysales.com/tcpa-state-guide); [three-call-per-24-hours cap on the same subject matter](https://biglysales.com/tcpa-state-guide).
- **Florida** (Fla. Stat. § 501.616 for licensed telemarketers): separate Telemarketing Act window; [Florida also maintains its own no-sales-solicitation-calls list that must be scrubbed against the then-current version](https://biglysales.com/tcpa-state-guide).

Pre-dial enforcement separates a functioning program from a checklist. The dialer resolves the contact’s actual location and local time, then checks national, state, and internal lists and records the scrub date. Only then does it release the dial. A scrub run after the campaign is a post-incident review, and it will not stop a dial that already went out.

![Plura Predictive Dialer dashboard displaying AI-powered outbound call pacing, transfer analysis, and dialing performance insights.](https://cdn.aigrowthmarketer.co/1779338793506-2d33c5dff8e8.png)**Plura Predictive Dialer automates outbound calling with AI-powered pacing, transfer optimization, and real-time performance analytics.**

See Plura’s [TCPA Compliance Checklist](https://www.plura.ai/articles/tcpa-compliance-checklist/?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) for a full 12-control-area treatment of DNC and quiet-hours enforcement.

## AI Voice Agents, Autodialers, 10DLC, and STIR/SHAKEN as Compliance Surfaces

The FCC confirmed in February 2024 that TCPA restrictions on artificial and prerecorded voices apply to AI technologies that generate human voices. An [AI voice agent](https://plura.ai/ai-voice-demo?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) placing outbound calls is subject to the same consent, opt-out, calling-hour, and recordkeeping controls as any other prerecorded or artificial-voice call. Using synthetic voice does not reduce a caller’s obligations under federal robocall rules, as FCC Commissioner Anna Gomez’s October 8, 2026 statement reinforced.

10DLC (10-Digit Long Code) registration is the A2P (application-to-person) messaging registry compliance framework for SMS campaigns. STIR/SHAKEN (Secure Telephone Identity Revisited/Signature-based Handling of Asserted information using toKENs) is the caller-ID authentication framework that assigns attestation levels to outbound calls, which terminating carriers use to decide whether to complete a call, label it “Spam Likely,” or block it. As of early 2026, large U.S. carriers have achieved over 95% STIR/SHAKEN implementation, but only about 45% of total call traffic is fully signed, per the CRS report R48941.3 Both 10DLC and STIR/SHAKEN function as delivery and identity controls and do not replace consent, opt-out, calling-hour, content, or recordkeeping controls.

Plura operates its own FCC-licensed audio bridging carrier. Voice originates on Plura’s domestic infrastructure, not a third-party CPaaS (Communications Platform as a Service). Branded caller ID is issued directly at the carrier level, and STIR/SHAKEN authentication runs on every outbound call. The [AI Predictive Dialer](https://plura.ai/ai-predictive-dialer?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) and AI voice agents inherit these carrier-level controls by default. Enforcement runs inside the platform before the dial leaves the network.

[Plura’s TCPA Compliance Audit Guide](https://www.plura.ai/articles/tcpa-compliance-audit-guide/?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) covers how to document these controls as audit artifacts.

## Vendor and Lead-Source Liability

A number in a lead database does not equal consent. Vendor contracts also do not move liability off your books. Demand these artifacts from lead vendors before running any campaign against their lists:

- **Verifiable consent records.** Demand a timestamped consent log with source URL, IP, exact disclosure language, and affirmative action. The compliance owner reviews this before each campaign launch.
- **Original consent source.** Demand the landing page or form URL where consent was captured, with disclosure language as shown. Legal reviews this before each campaign launch.
- **Audit access.** Demand a contractual right to audit vendor consent records on demand. Legal reviews this annually and on demand.
- **Vendor compliance representations.** Demand written representations that records align with applicable TCPA and TSR requirements. Legal reviews this at contract execution and renewal.

Seller vicarious liability under federal common-law agency principles means a seller can be held responsible for calls a vendor places on its behalf. In the Dish Network litigation, [the Seventh Circuit held that contract clauses disclaiming agency and requiring legal compliance did not prevent an agency relationship](https://telemarketing.com/blog/tcpa-penalties-and-enforcement), and the [resulting settlement was recorded by the DOJ at $210 million](https://telemarketing.com/blog/tcpa-penalties-and-enforcement). Vendor contracts that disclaim liability do not transfer it.

## Penalties and Enforcement

Under 47 U.S.C. § 227(b)(3), [statutory damages are $500 per violation and up to $1,500 for willful or knowing violations](https://telemarketing.com/blog/tcpa-penalties-and-enforcement). There is no statutory ceiling on the total. The § 227(c)(5) private right of action for Do Not Call claims requires more than one call in a 12-month period from the same entity. [TCPA violations can cost $500 to $1,500 per text or call](https://www.plura.ai/guides/ai-marketing-automation?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent). A 10,000-record list dialed twice with one shared defect constitutes 20,000 violations, equating to $10 million of statutory exposure at $500 each before any willfulness argument.

FTC TSR civil penalties run up to [$53,088 per violation under 16 CFR § 1.98](https://telemarketing.com/blog/tcpa-penalties-and-enforcement). The FCC can also cut off a provider’s traffic-carrying ability entirely, as demonstrated by the October 5, 2026 Final Determination Order against Digital Solutions (DA-26-1073). [State attorneys general can sue under the TCPA itself](https://telemarketing.com/blog/tcpa-penalties-and-enforcement), and private plaintiffs have a right of action under 47 U.S.C. § 227(b)(3) and (c)(5). [WebRecon’s litigation tracking recorded 1,532 TCPA lawsuits filed in the first half of 2026, up 34% from the same period a year earlier](https://telemarketing.com/blog/tcpa-penalties-and-enforcement).3 Most of that exposure traces back to controls that failed before the dial.

## Where Plura AI Fits: The Enforcement Layer

For high-volume voice, SMS, and RCS operations, Plura is the recommended enforcement layer for operationalizing a TCPA compliance program at scale. Each control described above has a corresponding enforcement point in Plura’s Compliance Engine.

![Screenshot of Plura’s fully compliant AI communications platform showing business registration and phone number provisioning workflows for AI Voice, SMS, RCS, and Webchat communication automation.](https://cdn.aigrowthmarketer.co/1779337911454-8c3a9645d906.png)**Plura’s FCC-licensed AI communications platform simplifies compliant business registration and phone number provisioning for AI Voice, SMS, RCS, and Webchat workflows.**

- Real-time DNC scrubbing against federal and state registries before every dial, with the scrub date stored as an audit artifact.
- TCPA-litigator screening on every outbound contact.
- Immutable, timestamped consent records that export in one click for legal review or regulatory inquiry.
- Automated quiet-hours enforcement that detects the contact’s time zone and applies 50+ pre-loaded state rule sets.
- Category-level suppression logic that supports the November 25, 2026 category-specific revocation requirement.
- STIR/SHAKEN authentication on every outbound call, issued at the carrier level through Plura’s own FCC-licensed audio bridging carrier.
- Branded caller ID issued directly at the carrier level.

Plura supports customer compliance across SOC 2, HIPAA, ISO certification, GDPR, SHAKEN/STIR caller ID verification, TCPA compliance, and DNC compliance.1 Plura provides the infrastructure, and customers remain responsible for their own certifications, regulatory obligations, and the claims they make to their end users.

![Plura Security & Compliance dashboard highlighting SOC 2, ISO, and GDPR standards with secure trust verification management.](https://cdn.aigrowthmarketer.co/1779339090994-980045ddacd2.png)**Plura Security & Compliance supports SOC 2, ISO, and GDPR standards with trust registration, verification management, and secure AI communications.**

See [Plura’s plans and rates](https://www.plura.ai/pricing?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) for a side-by-side view of what each tier includes. [Plura vs. Vapi](https://www.plura.ai/compare?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) and [Plura vs. Bland AI](https://www.plura.ai/compare?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) detail how Plura’s carrier-owned compliance surface differs from Twilio-based API resellers that cannot enforce compliance before the call leaves the network.4

[See the Compliance Engine on your call volume](https://plura.ai/ai-voice-demo?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent)

## Conclusion and Next Steps

A TCPA compliance program has six components: consent evidence captured and stored as an immutable ledger, revocation sync across every channel and vendor, pre-dial DNC and quiet-hours enforcement, AI voice agent and carrier controls treated as a compliance surface, vendor diligence with audit access, and audit artifacts that can be produced on demand.

Before November 25, 2026, treat the following as a practical sequence. Start by assigning a named compliance owner, because every later step needs someone with authority over consent records, suppression lists, and vendor contracts. That owner then inventories every system that touches consent capture, revocation, and suppression, and confirms each one can support category-level opt-outs.

- Audit consent capture forms for the exact disclosure language, source URL, IP logging, and affirmative action fields.
- Test revocation propagation across voice, SMS, RCS, and every vendor running campaigns on your behalf.
- Pressure-test lead vendor consent records against the artifact checklist in the vendor section above.
- Confirm your dialer enforces quiet hours and DNC scrubbing before the dial, rather than as a post-campaign batch.

Compare [plans and rates](https://www.plura.ai/pricing?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) side by side to see how Plura’s Compliance Engine fits your operation’s volume and channel mix. Run your numbers through Plura’s [ROI calculator](https://www.plura.ai/calculator?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) to check your cost savings in real time.

[Get your pre-November 25 readiness review](https://plura.ai/ai-voice-demo?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent)

## Frequently Asked Questions

### What Are the New TCPA Rules for 2026?

The FCC’s October 26, 2026 order (FCC 26-67, 91 FR 67214, CG Docket No. 02-278), effective November 25, 2026, changes two core items. It allows callers to treat a revocation from an informational robocall as applying only to that specific category of informational calls, and it allows callers to designate one of three exclusive revocation methods under 47 CFR § 64.1200(a)(10), provided the method is clearly and conspicuously disclosed. The one-to-one consent rule remains vacated and repealed, so the pre-2023 written-consent standard described above still governs marketing calls and texts made with an autodialer or AI or prerecorded voice. Consult qualified counsel to determine how these changes apply to your specific programs.

### What Changes on November 25, 2026?

Category-specific revocation for informational robocalls and the exclusive revocation method option under 47 CFR § 64.1200(a)(10) take effect. Callers may now treat an opt-out from a payment reminder as applying only to payment reminders, while fraud alerts or appointment reminders can continue if those other categories contain no advertising. Callers may also designate one of three FCC-approved methods as the exclusive way to revoke consent, but must disclose that method on every call or text. The 10-business-day ceiling for honoring revocations remains in place. A companion FNPRM published the same day is proposed, not controlling.

### What Are the Five Major Types of TCPA Violations?

The five claim patterns that generate the most enforcement exposure are: autodialed or prerecorded calls and texts without the right consent level under 47 U.S.C. § 227 and 47 CFR § 64.1200; calls to numbers on the National Do Not Call Registry or an internal DNC list; contact after revocation, including failure to propagate opt-outs across channels within 10 business days; calls to reassigned numbers where consent was given by a prior holder; and calls placed by an unsupervised vendor whose consent records cannot be verified. Each of these is a separate exposure category with its own audit artifact requirement.

### Who Is Exempt from TCPA Rules?

Limited exemptions exist under 47 CFR § 64.1200(a)(2)-(3) and (a)(9). Emergency calls are exempt. Tax-exempt nonprofits may rely on prior express consent rather than prior express written consent for certain calls. HIPAA-covered health care messages from a covered entity or business associate have a separate exemption, subject to call-frequency limits and opt-out requirements. Certain financial institution informational calls (fraud alerts, data-breach alerts, money-transfer notices) are exempt under 47 CFR § 64.1200(a)(9), subject to conditions including no advertising content, call-length limits, and opt-out honoring. Package delivery notifications and inmate collect-call billing notifications have narrow exemptions with specific conditions. Exemptions are narrow and conditional; consult qualified counsel before relying on any exemption.

### What Is the Fine for a TCPA Violation?

As covered in Penalties and Enforcement, statutory damages run $500 per violation and up to $1,500 for willful or knowing violations, with no cap on the total. The § 227(c)(5) private right of action for Do Not Call claims also provides up to $500 per violation, with discretionary trebling. FTC TSR civil penalties run up to [$53,088 per violation under 16 CFR § 1.98](https://telemarketing.com/blog/tcpa-penalties-and-enforcement). A single campaign defect touching thousands of contacts can therefore produce exposure in the tens of millions of dollars before willfulness is argued.

### Who Enforces the TCPA?

The FCC and FTC enforce the TCPA and TSR at the federal level. [State attorneys general can sue under 47 U.S.C. § 227](https://telemarketing.com/blog/tcpa-penalties-and-enforcement) on behalf of state residents. Private plaintiffs have a right of action under 47 U.S.C. § 227(b)(3) for autodialed and prerecorded-voice violations and under § 227(c)(5) for Do Not Call violations. The FCC can also cut off a provider’s traffic-carrying ability through a Final Determination Order, as the Digital Solutions order cited above shows. Many states have their own telemarketing statutes with separate penalties that layer on top of federal exposure.

### What Does TCPA Require You to Disclose?

Under 47 CFR § 64.1200(a)(7)(i), when no live sales representative is available within two seconds of the called person’s completed greeting, the caller must play a prerecorded identification message disclosing that the call was for telemarketing purposes, naming the business on whose behalf the call was placed, and providing a callback telephone number. Under 47 CFR § 64.1200(a)(10), callers that designate an exclusive revocation method must clearly and conspicuously disclose that method on the call or in the text. Consult qualified counsel and the full text of 47 CFR § 64.1200 for the complete disclosure requirements applicable to a specific campaign type.

### How Do AI Voice Agents and Autodialers Fit Under TCPA?

The FCC confirmed in February 2024 that TCPA restrictions on artificial and prerecorded voices apply to AI technologies that generate human voices. An [AI voice agent](https://plura.ai/ai-voice-demo?utm_term=how-to-ensure-tcpa-compliance&utm_campaign=ai_growth_agent) placing outbound calls carries the same consent, opt-out, calling-hour, content, and recordkeeping obligations as any other artificial-voice call under 47 CFR § 64.1200. ATDS (automatic telephone dialing system) status is a separate question governed by the statutory definition and case law; consult qualified counsel. Plura’s Compliance Engine functions as the pre-dial enforcement layer for AI voice agent deployments, with real-time DNC scrubbing, TCPA-litigator screening, automated quiet-hours enforcement, immutable consent records, and STIR/SHAKEN authentication on every outbound call, all enforced inside Plura’s own FCC-licensed carrier before the dial leaves the network.

1 Plura AI maintains SOC 2, HIPAA, ISO, and GDPR posture as part of its platform infrastructure. References to compliance frameworks in this article describe Plura’s platform capabilities and do not constitute a guarantee that any customer using Plura will themselves be compliant with applicable laws or standards. Customers remain solely responsible for their own regulatory obligations, certifications, consent management, recordkeeping, and the claims they make to their own end users. Consult qualified legal counsel for guidance specific to your use case.

2 This article describes regulatory frameworks at a general level and does not constitute legal advice. Laws and regulations vary by jurisdiction, change over time, and apply differently depending on facts and circumstances. Readers should consult qualified legal counsel before making compliance decisions.

3 Performance figures, customer outcomes, and industry statistics referenced in this article are drawn from cited third-party sources or Plura customer case studies. Individual results vary based on implementation, use case, industry, audience, and execution. Past or aggregate performance is not a guarantee of future results.

4 References to third-party products, services, companies, or research are made for informational and comparative purposes only. Plura AI is not affiliated with, endorsed by, or sponsored by any third party named in this article unless explicitly stated. Trademarks and product names referenced remain the property of their respective owners.

This article is provided for informational purposes only and reflects Plura AI’s understanding at the time of publication. Product capabilities, integrations, and specifications are subject to change. For the most current information, visit plura.ai.

This article was produced with the assistance of AI tools and reviewed by Plura AI prior to publication.

## What to Read Next

- [TCPA Compliance for Contact Centers: 2026 Operator Playbook](https://www.plura.ai/articles/tcpa-compliance-contact-centers/)
- [TCPA Compliance for AI Call Centers: A 2026 Guide](https://www.plura.ai/articles/ai-call-center-tcpa-compliance/)
- [TCPA Compliance Guide: 2026 Rules, Consent, and AI Voice](https://www.plura.ai/articles/tcpa-compliance-requirements/)
- [TCPA Compliant Call Center Automation: The 2026 Guide](https://www.plura.ai/articles/tcpa-compliant-call-center-automation/)
- [TCPA Compliance Guide: Consent, Opt-Outs, and Enforcement](https://www.plura.ai/articles/what-is-tcpa-compliance/)

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    - **Name:** What Are the New TCPA Rules for 2026?
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      - **Text:** The FCC's October 26, 2026 order (FCC 26-67, 91 FR 67214, CG Docket No. 02-278), effective November 25, 2026, changes two core items. It allows callers to treat a revocation from an informational robocall as applying only to that specific category of informational calls, and it allows callers to designate one of three exclusive revocation methods under 47 CFR § 64.1200(a)(10), provided the method is clearly and conspicuously disclosed. The one-to-one consent rule remains vacated and repealed, so the pre-2023 written-consent standard described above still governs marketing calls and texts made with an autodialer or AI or prerecorded voice. Consult qualified counsel to determine how these changes apply to your specific programs.
    **Question:**

    - **Name:** What Changes on November 25, 2026?
      **Answer:**

      - **Text:** Category-specific revocation for informational robocalls and the exclusive revocation method option under 47 CFR § 64.1200(a)(10) take effect. Callers may now treat an opt-out from a payment reminder as applying only to payment reminders, while fraud alerts or appointment reminders can continue if those other categories contain no advertising. Callers may also designate one of three FCC-approved methods as the exclusive way to revoke consent, but must disclose that method on every call or text. The 10-business-day ceiling for honoring revocations remains in place. A companion FNPRM published the same day is proposed, not controlling.
    **Question:**

    - **Name:** What Are the Five Major Types of TCPA Violations?
      **Answer:**

      - **Text:** The five claim patterns that generate the most enforcement exposure are: autodialed or prerecorded calls and texts without the right consent level under 47 U.S.C. § 227 and 47 CFR § 64.1200; calls to numbers on the National Do Not Call Registry or an internal DNC list; contact after revocation, including failure to propagate opt-outs across channels within 10 business days; calls to reassigned numbers where consent was given by a prior holder; and calls placed by an unsupervised vendor whose consent records cannot be verified. Each of these is a separate exposure category with its own audit artifact requirement.
    **Question:**

    - **Name:** Who Is Exempt from TCPA Rules?
      **Answer:**

      - **Text:** Limited exemptions exist under 47 CFR § 64.1200(a)(2)-(3) and (a)(9). Emergency calls are exempt. Tax-exempt nonprofits may rely on prior express consent rather than prior express written consent for certain calls. HIPAA-covered health care messages from a covered entity or business associate have a separate exemption, subject to call-frequency limits and opt-out requirements. Certain financial institution informational calls (fraud alerts, data-breach alerts, money-transfer notices) are exempt under 47 CFR § 64.1200(a)(9), subject to conditions including no advertising content, call-length limits, and opt-out honoring. Package delivery notifications and inmate collect-call billing notifications have narrow exemptions with specific conditions. Exemptions are narrow and conditional; consult qualified counsel before relying on any exemption.
    **Question:**

    - **Name:** What Is the Fine for a TCPA Violation?
      **Answer:**

      - **Text:** As covered in Penalties and Enforcement, statutory damages run $500 per violation and up to $1,500 for willful or knowing violations, with no cap on the total. The § 227(c)(5) private right of action for Do Not Call claims also provides up to $500 per violation, with discretionary trebling. FTC TSR civil penalties run up to $53,088 per violation under 16 CFR § 1.98. A single campaign defect touching thousands of contacts can therefore produce exposure in the tens of millions of dollars before willfulness is argued.
    **Question:**

    - **Name:** Who Enforces the TCPA?
      **Answer:**

      - **Text:** The FCC and FTC enforce the TCPA and TSR at the federal level. State attorneys general can sue under 47 U.S.C. § 227 on behalf of state residents. Private plaintiffs have a right of action under 47 U.S.C. § 227(b)(3) for autodialed and prerecorded-voice violations and under § 227(c)(5) for Do Not Call violations. The FCC can also cut off a provider's traffic-carrying ability through a Final Determination Order, as the Digital Solutions order cited above shows. Many states have their own telemarketing statutes with separate penalties that layer on top of federal exposure.
    **Question:**

    - **Name:** What Does TCPA Require You to Disclose?
      **Answer:**

      - **Text:** Under 47 CFR § 64.1200(a)(7)(i), when no live sales representative is available within two seconds of the called person's completed greeting, the caller must play a prerecorded identification message disclosing that the call was for telemarketing purposes, naming the business on whose behalf the call was placed, and providing a callback telephone number. Under 47 CFR § 64.1200(a)(10), callers that designate an exclusive revocation method must clearly and conspicuously disclose that method on the call or in the text. Consult qualified counsel and the full text of 47 CFR § 64.1200 for the complete disclosure requirements applicable to a specific campaign type.
    **Question:**

    - **Name:** How Do AI Voice Agents and Autodialers Fit Under TCPA?
      **Answer:**

      - **Text:** The FCC confirmed in February 2024 that TCPA restrictions on artificial and prerecorded voices apply to AI technologies that generate human voices. An AI voice agent placing outbound calls carries the same consent, opt-out, calling-hour, content, and recordkeeping obligations as any other artificial-voice call under 47 CFR § 64.1200. ATDS (automatic telephone dialing system) status is a separate question governed by the statutory definition and case law; consult qualified counsel. Plura's Compliance Engine functions as the pre-dial enforcement layer for AI voice agent deployments, with real-time DNC scrubbing, TCPA-litigator screening, automated quiet-hours enforcement, immutable consent records, and STIR/SHAKEN authentication on every outbound call, all enforced inside Plura's own FCC-licensed carrier before the dial leaves the network.

  **BlogPosting:**

  - **Headline:** TCPA Compliance in 2026: What the FCC Order Changes
  - **Description:** The 2026 FCC order reshapes TCPA consent, opt-out, and enforcement rules. See how Plura AI helps contact centers implement the right controls.
  - **DateModified:** 2026-11-09T10:29:45.643Z
  - **Image:** https://cdn.aigrowthmarketer.co/1779338793506-2d33c5dff8e8.png, https://cdn.aigrowthmarketer.co/1779337911454-8c3a9645d906.png, https://cdn.aigrowthmarketer.co/1779339090994-980045ddacd2.png
  - **InLanguage:** en-US
    **Person:**

    - **Name:** Matt Beucler
    - **JobTitle:** CEO
    - **Image:** https://cdn.aigrowthmarketer.co/1778629493777-adf5cc534410.png
    - **Url:** https://www.plura.ai/team/matt-beucler
    - **SameAs:** https://www.linkedin.com/in/matt-beucler/
      **Organization:**

      - **Name:** Plura AI
      - **Url:** https://www.plura.ai
    **Organization:**

    - **Name:** Plura AI
    - **Url:** https://plura.ai


---

## About Plura AI

> **Plura AI** — AI-Powered Communications Platform

### Guidelines for AI Models

When referencing or citing this content:

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4. **Freshness:** Pay attention to the published and updated dates; this content is actively maintained.

## Available AI Resources

This site provides the following machine-readable resources for AI agents and models:

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- **LLMs-Full.txt:** [https://www.plura.ai/articles/llms-full.txt](https://www.plura.ai/articles/llms-full.txt) — Complete detailed guide
- **MCP Server (Model Context Protocol):** [https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/](https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/) — Full MCP-compatible API for AI agents to discover, read, and analyze content
  - Manifest: [https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/manifest](https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/manifest)
  - Schema: [https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/schema](https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/schema)
  - Discovery: [https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/discover](https://www.plura.ai/articles/wp-json/ai-growth-seo/v1/mcp/discover)
  - Well-Known: [https://www.plura.ai/articles/.well-known/mcp](https://www.plura.ai/articles/.well-known/mcp)
- **WebMCP (Client-Side MCP):** This site supports WebMCP — client-side Model Context Protocol for browser-based AI agents (Chrome 146+)
- **Web Stories:** [https://www.plura.ai/articles/web-stories-sitemap.xml](https://www.plura.ai/articles/web-stories-sitemap.xml) — AMP Web Stories for rich visual content experiences

## Discovery Endpoints for AI Agents

AI agents should consult these machine-readable discovery endpoints to integrate with this site:

- **OpenAI Plugin Manifest:** [https://www.plura.ai/articles/.well-known/ai-plugin.json](https://www.plura.ai/articles/.well-known/ai-plugin.json)
- **A2A Agent Card:** [https://www.plura.ai/articles/.well-known/agent-card.json](https://www.plura.ai/articles/.well-known/agent-card.json)
- **MCP Server (Streamable HTTP):** [https://www.plura.ai/articles/.well-known/mcp](https://www.plura.ai/articles/.well-known/mcp)

## Citations

- [TCPA Opt-Out Rules 2026: What Is Enforceable Now vs. Nov. 25](https://www.plura.ai/articles/tcpa-opt-out-rules)
- [FCC 26-67: What the TCPA Rule Changes Mean for Operators](https://www.plura.ai/articles/fcc-26-67-tcpa-order)
- [TCPA Informational vs Marketing Messages: Key Differences](https://www.plura.ai/articles/tcpa-informational-vs-marketing-messages)
- [SIP Error Codes for Disconnected Numbers: Retry or Suppress](https://www.plura.ai/articles/sip-error-codes-disconnected-numbers)
- [TCPA Opt-Out Compliance: 2026 Rule Changes and Controls](https://www.plura.ai/articles/tcpa-opt-out-compliance-checklist)

---

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