Texting customers legally: TCPA consent, 10DLC and quiet hours for contractors

Texting customers legally comes down to three questions you can answer before any message leaves the building: what kind of text is this, what did the customer agree to, and what time is it where their phone is. Get those right and you can text appointment reminders, on-my-way alerts, invoices and even promotions without fear. Get them wrong and the math turns ugly fast: the TCPA lets a consumer sue for $500 per message, up to $1,500 if the violation was willful,¹ and a few states have copied that model.

This post gives you a working system, not a law school outline: a consent ladder that sorts every text a service company sends, a quiet-hours rule that covers the strict states, and a STOP process that holds up. Rule status below was checked against FCC, Federal Register and state sources on October 15, 2026, including the FCC order adopted September 30, 2026.

The three laws, rules and gatekeepers that govern business texting

Texting a customer touches three separate rulebooks, and owners tend to blur them together.

The carrier layer is the one most contractors meet first, because it fails loudly. The legal layers fail quietly until a demand letter shows up.

Why texts count as calls (mostly)

The TCPA was written in 1991, before anyone texted. For years, courts and the FCC treated a text message as a "call" for the TCPA's autodialer and prerecorded-voice rules. That still largely holds for the consent rules. But in July 2026 the Seventh Circuit held in Steidinger v. Blackstone Medical Services that texts are not "telephone calls" under the TCPA's do-not-call private right of action, Section 227(c)(5).² That ruling binds federal courts in Illinois, Indiana and Wisconsin only, other courts have gone the other way, and the Supreme Court's 2025 McLaughlin decision means district courts no longer have to follow the FCC's reading of the statute.³

Translation for an owner: the federal law is in flux, and the state laws were rewritten specifically to cover texts. Build your process as if every rule applies to texts. It costs you almost nothing.

The consent ladder: match every text to the consent it needs

The cleanest way to think about consent comes from the carriers themselves. CTIA's Messaging Principles sort business texts into three types, each with its own consent level.⁴ We've mapped the texts a service company actually sends onto that ladder.

Two details in that table do most of the work.

Adding an offer changes the category. CTIA is explicit that a call to action, such as a coupon code added to an informational text, can push the message into the promotional category.⁴ The FCC's rules draw the same line: a call that "includes or introduces an advertisement or constitutes telemarketing" needs prior express written consent when it's sent with an autodialer or an artificial voice.⁵ The easiest way to stay out of trouble is to keep reminders boring and keep promotions in their own messages, sent only to people who signed up for them.

"Written" doesn't mean paper. The FCC defines prior express written consent as a written agreement bearing the customer's signature that authorizes marketing messages to a specific number, and it must make clear the customer isn't required to agree as a condition of buying anything.⁵ Electronic signatures count, including a checked box on a web form or tablet. What doesn't count: consent buried in your invoice terms, or a box that's pre-checked.

Write consent language that covers what you actually send

Most contractors capture consent in one of four places: the online booking form, the call (CSR reads it), the estimate or agreement the customer signs, and the membership signup. Each should say plainly which texts the customer will get. A sample for a booking form, which you should have your own attorney review:

Text me about this appointment (confirmations, arrival times, invoices). Required to book online.

☐ Also text me service reminders and offers from [Company] at the number above. Messages may be sent using automated technology. Consent is not a condition of purchase. Msg and data rates may apply. Reply STOP to opt out, HELP for help.

Note the split. The first line covers informational texts tied to the job. The second is an unchecked box for marketing, separate from the purchase. When you later run a tune-up campaign, you text only the customers who ticked that second box.

CTIA lists the same kind of records: when consent was captured and through what medium.⁴ If you ever get a demand letter, this record is your whole defense. A screenshot of the form as it looked that month, saved with a version number, is worth more than any policy document.

Quiet hours: the federal rule and the stricter states

The FCC's rule bars telephone solicitations to a residential subscriber "before the hour of 8 a.m. or after 9 p.m." local time at the called party's location.⁵ Since late 2024 a handful of plaintiffs' firms have filed a wave of class actions over marketing texts that arrived early in the morning or late at night, often to people who had signed up for them. In March 2025 an e-commerce trade group asked the FCC to confirm that customers who gave written consent can't sue over quiet hours. As of the latest reports we could find (May 2026), the FCC hadn't ruled.⁷ The first reported court decision, King v. Bon Charge in Delaware federal court on April 30, 2026, held that texts a customer had consented to were not "telephone solicitations," so the quiet-hours rule didn't apply.⁷ That's one district court. Don't build your send schedule on it.

Several states are tighter than the federal rule.

Oklahoma's law specifically defines its sales calls to include those placed "by telephone call, text message, or voicemail," and Maryland's does the same.⁹¹⁰ Texas joined the group on September 1, 2025, when SB 140 extended the state's telephone-solicitation law to text messages and gave consumers a private right of action under the Deceptive Trade Practices Act. The Texas attorney general later said consent-based text programs aren't subject to the state's registration requirement, but the private-action exposure remains.¹¹

Rather than tracking every state, adopt a house rule: promotional texts go out between 8 a.m. and 8 p.m. in the customer's time zone, no more than one per day. That clears every row in the table. For a shop near a state line or with customers who've moved, use the service address's time zone and remember Maryland presumes anyone with a Maryland area code is a Maryland resident.¹⁰

What about informational texts? An on-my-way at 7:40 a.m. for an 8 a.m. arrival window isn't a solicitation, and the quiet-hours rule is written for solicitations. But a reminder that also pitches a duct cleaning is a solicitation with a reminder attached. Keep them apart.

STOP means stop: revocation rules as of October 2026

Opt-outs are where the rules changed most in the last two years, so here is the timeline.

1. April 11, 2025

   Any reasonable method, 10 business days

   The FCC's 2024 consent order took effect: customers may revoke consent by any reasonable means, STOP, QUIT, END, REVOKE, OPT OUT, CANCEL or UNSUBSCRIBE are per se valid replies, and callers must honor revocations within 10 business days.

2. April 2025 and January 2026

   The 'revoke all' piece delayed

   The FCC's consumer bureau twice delayed the part that would make one opt-out stop every unrelated informational message, most recently to January 31, 2027 (DA 26-12).

3. September 30, 2026

   FCC adopts a narrower revocation rule

   FCC 26-67 lets callers treat an opt-out from one category of informational messages as applying to that category only, and lets callers designate an exclusive opt-out method, such as reply STOP, if it's disclosed in each message. It takes effect 30 days after Federal Register publication.

4. Still true

   Marketing opt-outs cover all marketing

   Under the new order, a revocation in response to a marketing message revokes consent for all future marketing from that caller.

Sources for the timeline: the 2024 order as published in the Federal Register,¹² the January 2026 waiver,¹³ and FCC 26-67 itself, adopted September 30 and released October 1, 2026.¹⁴ When we checked on October 15, 2026, the new order had not yet appeared in the Federal Register, so its effective date isn't set. The FCC said it will announce the date by public notice.

For a contractor, the 2026 order is good news with a catch. The good news: a customer who replies STOP to your tune-up promotion can still get the on-my-way text for the repair they booked next month, because those are different categories. The catch: you only get that treatment if your system actually tracks categories and processes opt-outs automatically. If your texting tool has one global opt-out flag, assume one STOP stops everything.

1. 1

   Process the keywords instantly

   STOP, QUIT, END, REVOKE, OPT OUT, CANCEL and UNSUBSCRIBE should flip the flag the moment they arrive. CTIA also asks senders to honor plain-language requests and ignore differences in capitalization.

2. 2

   Send one confirmation, then silence

   CTIA allows a single opt-out confirmation. Don't use it to ask why, and don't include an offer.

3. 3

   Catch the non-keyword opt-outs

   'Please stop texting me' and 'take me off your list' are revocations under the any-reasonable-means rule that still applies today. Someone in the office needs to review replies daily.

4. 4

   Sync the flag everywhere

   If a customer opts out in your texting tool, your marketing tool, your review tool and your CSR's phone all need to know. Most violations here are a second system that didn't get the memo.

5. 5

   Keep do-not-call requests for five years

   The FCC requires entity-specific do-not-call requests to be honored for five years from the date they're made.

The five-year retention period comes from the FCC's do-not-call rule.⁵ And keep in mind the established business relationship exemption that lets you call existing customers despite the National Do Not Call Registry runs only 18 months after their last purchase, or 3 months after an inquiry.⁵ A customer you last served in 2023 isn't an existing customer for that purpose.

10DLC registration: the carrier layer

Every text you send from an ordinary local business number travels as "A2P 10DLC" traffic: application-to-person, 10-digit long code. Carriers require you to register two things through The Campaign Registry before that traffic flows:

• A brand: your legal business name, EIN, address and website, so carriers can confirm you're a real sender.
• A campaign: what you'll send (customer care, account notifications, marketing, or mixed), sample messages, how customers opt in, and your opt-out and help responses.

Unregistered traffic doesn't get far. Twilio, a messaging provider many business texting tools run on, says it blocks messages to U.S. numbers sent from a 10DLC number that isn't associated with an approved campaign.¹⁵ Its documentation also notes that the sole-proprietor registration, meant for very small senders without an EIN, is capped at one campaign and about 1,000 message segments a day to T-Mobile.¹⁶

Two practical tips from watching shops go through this:

1. Describe your opt-in exactly as it works. Reviewers reject campaigns where the website has no visible consent language. Put the checkbox wording from earlier on your booking page before you submit.
2. Register "mixed" if you'll ever send promotions. A campaign registered only for appointment notifications that starts sending tune-up specials is out of scope, and carriers filter for it.

TradesWork registers business texting for your number during setup; until registration is approved, texting shows Limited and texts aren't sent, which is the honest failure mode. Approval usually takes a few days, sometimes about two weeks.

What about AI texts and AI voices?

If an AI agent replies to your leads by text, the consent rules above apply to it exactly as they apply to a CSR. The FCC ruled in February 2024 that AI-generated voices count as "artificial" voices under the TCPA, so an AI phone call to a mobile number needs the same consent as a prerecorded one.¹⁷ Our post on AI-written reviews, texts and calls goes deeper.

In TradesWork, the lead text agent only texts website, webhook, Facebook and Zapier leads that carry the customer's texting consent, and opt-outs, complaints and emergencies go straight to a person. That's a design choice worth asking any vendor about.

The one-page texting policy

Print this, put it in the CSR binder and review it every January.

For the rest of the stack, see our guide to speed to lead, which is where most first texts happen, and using your job history for marketing, which is where most promotional texts go wrong. Missed-call text-back and quiet-hours holds are covered on the phones feature page.

This post is general information, not legal advice. TCPA exposure depends on facts and on the states you serve; have counsel review your consent language before you launch a marketing program.