Federal law restricts telephone solicitations to between 8 a.m. and 9 p.m. at the called party's local time (47 C.F.R. § 64.1200(c)(1)), requires scrubbing against both the national do-not-call registry and your own internal list, and requires revocation requests to be honored within a reasonable time not exceeding ten business days (§ 64.1200(a)(10)). The FCC's one-to-one consent rule was vacated by the Eleventh Circuit on January 24, 2025 and removed from the rules. The broader “revoke-all” requirement has been extended to January 31, 2027. Rules below were verified against the Code of Federal Regulations and FCC orders in August 2026.
This Is Not Legal Advice
It needs saying at the top rather than in small print at the bottom. This article is general information for dealership managers, written to help you ask your own counsel better questions. It is not legal advice, it does not create any advisory relationship, and it cannot account for your state, your vendor contracts or the specific way your store operates.
Every rule cited below is named and linked to its source so you can check it yourself, and the article is dated. Telephone consumer protection law moves — three of the points below changed in the last twenty months — so if you are reading this well after August 2026, verify before you rely on it.
What the TCPA Covers
The Telephone Consumer Protection Act, codified at 47 U.S.C. § 227 with the implementing rules at 47 C.F.R. § 64.1200, governs telemarketing calls, texts, prerecorded messages and autodialed contact. For a dealership it reaches essentially all outbound work: the BDC calling unsold leads, the service department's reminder texts, the equity mining campaign, and the third-party call center working your database.
That last one matters more than most managers realize. Liability under the TCPA extends to calls made on behalf of a seller. Hiring a vendor does not move the exposure onto the vendor, and a dealership that has never checked how its outsourced phone room handles opt-outs is carrying a risk it cannot see. If you use an outside call center — including ours — ask them for their do-not-call procedure, their revocation handling and their scrub cadence in writing.
Calling Hours: 8 a.m. to 9 p.m., Their Time
The rule is short. Under 47 C.F.R. § 64.1200(c)(1), no person may initiate a telephone solicitation to a residential telephone subscriber “before the hour of 8 a.m. or after 9 p.m. (local time at the called party's location)”.
The phrase doing the work is local time at the called party's location. Not your store's time, not your dialer's server time, and not the area code's nominal time zone — which, given how many people keep a number after moving, is a genuinely unreliable proxy. A store in Charlotte starting outbound at 8 a.m. Eastern is calling a customer in California at 5 a.m.
There is a nuance here that gets misused, so it is worth stating carefully. The restriction applies to a “telephone solicitation”, and the regulation's definition of that term at § 64.1200(f) excludes calls made with the person's prior express invitation or permission, calls to a person with whom the caller has an established business relationship, and calls by or for a tax-exempt nonprofit. Some callers read that as license to call an existing customer at 6 a.m. That reading is contested rather than settled, it is the subject of active litigation, and off-hours messaging is currently one of the most heavily filed claim types. The defensible operating position is simple: observe 8 a.m. to 9 p.m. in the customer's local time for everything, and configure your dialer to enforce it rather than relying on agents to remember.
Two Do-Not-Call Lists, Not One
Stores routinely have one and assume it covers them.
The national registry. Section 64.1200(c)(2) prohibits solicitation calls to a residential subscriber registered on the national do-not-call registry. There are exceptions — including an established business relationship, and prior express invitation or permission evidenced by a signed written agreement naming the seller and the number to be called — but the operational point is the safe harbor: it requires using a version of the registry obtained from the administrator no more than 31 days before the call. A scrub you ran last quarter does not qualify.
The established business relationship itself is defined in the regulation and it has a clock on it: a purchase or transaction within the preceding 18 months, or an inquiry or application about your products or services within the preceding 3 months, and only where neither party has terminated the relationship. A customer who bought from you four years ago is not an EBR.
Your internal list. Section 64.1200(d) requires a separate, company-specific list, and it is prescriptive about the procedures: a written policy, personnel training, recording the request when it is made, and honoring it “within a reasonable time” that “may not exceed ten (10) business days from the receipt of such request”. A do-not-call request must be honored for 5 years.
The practical failure mode in dealerships is not refusing to honor a request. It is honoring it in one system. A customer tells a service advisor to stop calling; the advisor notes it in the service file; the sales BDC, working from the CRM, calls them the following week. That is a violation, and it is entirely ordinary.
Revocation: Seven Words and Ten Business Days
Section 64.1200(a)(10) governs how a consumer takes consent back. A revocation can be made through any reasonable method, and the rule specifically names replies using the words “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe.” The request must be honored within a reasonable time not exceeding ten business days from receipt.
Two things follow. First, your text platform has to recognize all of those words and not only whichever one your vendor's documentation happens to mention. Second — and this is where dealerships get caught — a revocation delivered by a reasonable method has to be honored even when it does not arrive through the channel you would prefer. A customer who replies “stop” to a service reminder, or tells an agent on a call, has revoked. The obligation does not depend on them using your web form.
Where the One-to-One Consent Rule Ended Up
This is the item most often still wrong in dealer training decks, in both directions.
The FCC adopted a rule that would have required lead-generator consent to name a single identified seller, rather than one consent covering a list of marketing partners, and would have required calls to be logically and topically associated with the interaction that produced the consent. It was set to take effect on January 27, 2025.
On January 24, 2025, three days before it would have applied, the Eleventh Circuit vacated it in Insurance Marketing Coalition Ltd. v. FCC, holding that the FCC had exceeded its statutory authority by altering the common-law meaning of “prior express consent.” The FCC has since removed the vacated language from its rules, and the consent standard reverted to what it was before.
What that means for a dealership buying leads: the one-to-one requirement is not in force, and you are not obliged to source leads that carry single-seller consent. What it does not mean is that consent stopped mattering. Prior express written consent is still required for autodialed or prerecorded marketing calls and texts, and a lead form whose consent language is vague about who may call is still a weak document to be holding when a claim arrives. Several state statutes also impose their own consent requirements that this decision did not touch.
The Revoke-All Requirement Has Been Pushed to 2027
A separate part of the FCC's revocation rules would require a caller who receives a revocation in response to one kind of message to treat it as applying to all future calls and texts from that caller, including on unrelated subjects. For a dealership that is a significant operational change: a “stop” to a service reminder would end sales marketing too.
Its effective date has moved twice. It was originally April 11, 2025, was extended to April 11, 2026, and on January 6, 2026 the FCC's Consumer and Governmental Affairs Bureau extended it again to January 31, 2027.
Two cautions. The extension applies only to that specific requirement — every other part of the revocation rules, including the seven opt-out words and the ten-business-day deadline, is already in force. And a store that builds toward cross-channel opt-out now will be better off in January 2027 than one that waits, because unifying opt-out across a CRM, a DMS, a texting platform and a call center is not a switch you flip.
What It Costs to Get Wrong
Under 47 U.S.C. § 227(b)(3) a private plaintiff may recover actual monetary loss or $500 for each violation, whichever is greater, and a court may in its discretion increase the award to up to three times that amount for a willful or knowing violation. Section 227(c)(5) provides a parallel action for someone who received more than one call in a 12-month period in violation of the do-not-call regulations, on the same damages structure.
Per violation means per call or per text. A dialer misconfiguration that runs for a week across a few thousand records is not a $500 problem.
There is one piece of good news in the statute, and it is the reason the paperwork matters. Section 227(c)(5) provides an affirmative defense where the defendant has established and implemented, with due care, reasonable practices and procedures to effectively prevent violations. A written do-not-call policy, documented training and a demonstrable scrub cadence are not bureaucracy — they are the defense.
Your State Probably Goes Further
Federal law is the floor. A number of states — Florida, Oklahoma, Maryland and Connecticut among them — have their own telemarketing statutes that impose stricter requirements than the TCPA, and several carry their own private rights of action, which is what makes them attractive to plaintiffs' firms.
We are deliberately not publishing the specifics of any state's rules here, because they differ from the federal ones in ways that matter and several have been amended recently. If you call into more than one state — and any dealership with a database of past customers does — the question of which state's rules apply to which record is one to put to your counsel before the next campaign, not after it.
A Practical Checklist
None of this is exotic. Most dealership exposure comes from four ordinary gaps.
One. Configure the dialer to enforce 8 a.m. to 9 p.m. by the customer's location, not the area code, and not the store's clock.
Two. Scrub against the national registry on a cadence that never exceeds 31 days, and keep the evidence that you did.
Three. Make the internal do-not-call list a single list that every system reads — CRM, DMS, texting platform and any outside call center. One opt-out, everywhere, honored inside ten business days and kept for five years.
Four. Put the policy in writing, train to it, and keep the training records. That paperwork is the § 227(c)(5) defense.
If you want an outside read on how your store actually handles this in practice rather than on paper, an in-store assessment looks at the process end to end, and our Sales BDC training covers opt-out handling as part of phone process.
Frequently Asked Questions
What are the legal calling hours for a dealership BDC?
Under 47 C.F.R. § 64.1200(c)(1), telephone solicitations to a residential telephone subscriber may not be initiated before 8 a.m. or after 9 p.m., measured by local time at the called party's location rather than the caller's. Because area codes are an unreliable guide to where someone actually lives, and because off-hours claims are being filed heavily, the defensible practice is to enforce that window in the dialer for all outbound campaigns rather than relying on any exemption.
Is the FCC one-to-one consent rule still in effect?
No. The rule would have required lead-generation consent to identify a single seller and to be logically and topically associated with the originating interaction, and was due to take effect on January 27, 2025. The Eleventh Circuit vacated it on January 24, 2025 in Insurance Marketing Coalition Ltd. v. FCC, finding the Commission had exceeded its statutory authority, and the FCC subsequently removed the vacated language from its rules. Prior express written consent is still required for autodialed and prerecorded marketing calls and texts, and several state statutes impose consent requirements that the decision did not affect.
How quickly must a dealership honor an opt-out request?
Within a reasonable time not exceeding ten business days from receipt. That deadline applies both to revocation of consent under 47 C.F.R. § 64.1200(a)(10) and to company-specific do-not-call requests under § 64.1200(d)(3). A company-specific do-not-call request must then be honored for five years from the date it was made.
Which words does a customer have to use to opt out of dealership texts?
Revocation can be made by any reasonable method, and the rule at 47 C.F.R. § 64.1200(a)(10) specifically identifies replies using the words stop, quit, end, revoke, opt out, cancel or unsubscribe. A texting platform that recognizes only some of those, or that requires the customer to use a web form instead, does not meet the requirement.
Does the TCPA apply to an outsourced call center working for a dealership?
Yes, and it also reaches the dealership. Liability extends to calls made on behalf of a seller, so contracting the work out does not move the exposure onto the vendor alone. Any dealership using an outside phone room should obtain that vendor's do-not-call procedure, revocation handling and registry scrub cadence in writing, and confirm that opt-outs recorded by the vendor flow back into the store's own systems.
What is the current status of the FCC revoke-all requirement?
It has been delayed. The requirement — that a revocation received in response to one type of message be treated as applying to all future calls and texts from that caller, including on unrelated subjects — was originally to take effect on April 11, 2025, was extended to April 11, 2026, and on January 6, 2026 the FCC's Consumer and Governmental Affairs Bureau extended it again to January 31, 2027. The extension covers only that requirement; the rest of the revocation rules, including the opt-out words and the ten-business-day deadline, are already in force.
Summary
The federal rules a dealership BDC has to live inside are a short list: an 8 a.m. to 9 p.m. window in the customer's time zone, a national registry scrub no older than 31 days, an internal do-not-call list honored within ten business days and kept for five years, and revocation recognized in seven words through any reasonable channel. The one-to-one consent rule is gone; the revoke-all requirement is coming in January 2027. Written procedures and training records are not overhead — under § 227(c)(5) they are the affirmative defense. Everything above was verified against the Code of Federal Regulations, 47 U.S.C. § 227 and FCC orders in August 2026, and none of it is a substitute for advice from your own attorney.