If you run SMS programs at scale, the last twelve months have been a reminder that the compliance ground never stays still for long. A quick tour of where things stand heading into 2026:
The FCC's "one-to-one consent" rule is off the table — vacated by the Eleventh Circuit in early 2025 and formally abandoned by the FCC later that year. What looked like a major shift in how leads could be sold and messaged turned into a non-event.
The "revocation-all" provision has been delayed — originally scheduled to take effect in April 2026, the FCC pushed the compliance date to January 31, 2027. That gives senders breathing room, but it doesn't take the rule off the radar.
State-level activity is where most of the motion is — Florida, Washington, Oklahoma, Maryland, and a growing list of others have passed or updated "mini-TCPA" statutes with their own consent, timing, and disclosure requirements. National campaigns increasingly live or die on how well they handle state-by-state variation.
Revocation handling is the new battleground — regardless of the federal delay, carriers and mailbox providers are already raising the bar on how quickly opt-outs are recognized and honored across channels.
Where we come in
None of this is meant to be a legal primer — we're not your lawyers, and compliance conversations always have to run through counsel. What we do is help our clients design SMS programs that are built to flex as the rules flex. That means consent capture that holds up in audit, suppression logic that crosses channels, real-time monitoring of complaint rates, and a team that's paying attention when the next update drops.
The short version: SMS is still one of the highest-intent channels available to performance marketers, and the brands that treat compliance as a core competency — not an afterthought — are the ones scaling through changes like these without losing a step.
If SMS is part of your 2026 plan, let's talk.
