2025 TCPA Regulations: What You Need to Know About Updated Opt-Out Rules   

Are you prepared for 2025? The Federal Communications Commission (FCC) is introducing major changes to the Telephone Consumer Protection Act (TCPA), and businesses that fail to adapt could face devastating consequences. We’re talking lawsuits costing millions, reputation damage that may be impossible to rebuild, and the crippling fear of becoming the next cautionary tale.

The new TCPA rules aim to give consumers more power while holding businesses accountable. If your outreach involves calls or texts, ignoring these changes could leave you vulnerable against a growing wave of litigation.

TCPA class action filings have reached alarming levels. In April 2024 alone, 92 class actions were filed, accounting for 68.1% of all TCPA cases that month—the highest percentage ever. From January to April 2024, filings surged by 39% compared to the same period in 2023. These numbers underscore a harsh reality: the risks are growing, and businesses can no longer afford complacency.

Non-compliance could lead to devastating financial penalties, reputational harm, and irreversible damage to your brand’s credibility. The time to act is now.

What’s Changing in 2025?   

1.  One-to-One Consent

Starting January 27, 2025, the FCC will require businesses to secure explicit, written consent for robocalls and robotexts directly from consumers. This closes the “lead generator loophole,” where a single consent agreement could apply to multiple marketers.

Key points include:

• Businesses must gather consent for their outreach purposes.
• Shared consent agreements covering multiple companies will no longer be valid.
• All communication must align with the context of the consumer’s original consent.

This rule poses significant challenges for companies relying on third-party leads or shared consent agreements, as they must ensure every lead meets the new standard.

2. Opt-Outs Must Be Flexible 

As of April 11, 2025, consumers can opt out of communications using any reasonable method. Whether it’s a simple “Stop,” “No more texts,” or “Remove me,” businesses must honor the request. Non-compliance with this requirement could lead to immediate legal action, further emphasizing the need for responsive and reliable systems to manage opt-out requests.

3. Shorter Processing Time for Requests 

Businesses will have 10 business days to process opt-out or do-not-call requests starting April 11, 2025. Delays or system issues that result in unwanted contact after an opt-out will increase legal exposure. Ensuring that your systems are seamless and error-free has never been more critical.

TCPA Cases in 2024

 1. Visalus  

Visalus’s filed for bankruptcy in 2024, which serves as a sobering reminder of what can happen when businesses fail to understand and adapt to evolving TCPA regulations. The company faced a staggering $920 million TCPA judgment due to non-compliance with consent requirements—a financial blow so severe it led to their eventual downfall.

What went wrong? Visalus did not account for the fact that the FCC’s updated consent rules retroactively applied to agreements obtained before the new regulations became effective. This misunderstanding proved fatal. Businesses that rely on outdated or improperly obtained consent are at significant risk, especially as the one-to-one consent rule becomes effective on January 27, 2025.

This is a stark warning for lead buyers and marketers across industries. Purchasing third-party leads or operating under blanket consent agreements without verifying their validity could expose businesses to devastating legal and financial consequences. The same mistakes that brought down Visalus are poised to repeat if companies fail to act now.

2. Blue Cross and Blue Shield 

Blue Cross and Change Healthcare faced a class action lawsuit for making unauthorized robocalls to residents in North Carolina. The calls, which lacked proper express consent, violated TCPA provisions requiring prior consent for automated communications.

Alexandra Stark, the lead plaintiff, initiated the lawsuit in 2023, citing that the companies failed to obtain explicit permission before placing the calls. The case concluded with a $1.6 million settlement in 2024, emphasizing the liability of healthcare organizations and their third-party vendors for ensuring comprehensive and compliant consent frameworks.

For companies in the healthcare industry, this case highlights the importance of scrutinizing consent practices and thoroughly vetting third-party communication vendors.

3. DoorDash 

DoorDash became embroiled in a TCPA violation lawsuit after plaintiff Johnson reported receiving persistent, unsolicited calls using a prerecorded voice. These calls, urging her to sign up as a restaurant owner, occurred daily starting in February 2023, sometimes multiple times a day, even as early as 7:00 AM. The calls continued despite

Johnson’s repeated attempts to opt out, including contacting DoorDash’s customer support and filing complaints with the FCC. This non-compliance with TCPA provisions, including honoring internal Do Not Call (DNC) requests and adhering to time restrictions, could result in significant penalties, with statutory damages ranging from $500 to $1,500 per violation.

This case serves as a wake-up call to companies heavily reliant on outbound marketing—ignoring opt-out requests is no longer an option.

4. Twilio 

Twilio, a leading cloud communications platform, faced allegations of originating hundreds of robocalls and text messages to a consumer’s phone number listed on the National Do Not Call Registry.

Plaintiff Michael Anthony claimed that Twilio’s services were misused to facilitate these illegal communications despite repeated opt-out requests. The case highlights the responsibility of communication platforms to ensure that their infrastructure is not exploited for non-compliant practices, potentially exposing providers to liability.

Companies relying on cloud communication platforms must prioritize working with vendors that enforce robust compliance safeguards.

5. Citibank 

Citibank agreed to a $29.5 million settlement after being accused of making unauthorized robocalls to customers regarding overdue credit card accounts. The lawsuit, which covered robocalls made over a decade (from August 15, 2014, to July 31, 2024), alleged that Citibank failed to obtain prior express consent before using automated dialing systems.

This case underscores the financial risks of long-term non-compliance and the importance of regularly auditing communication practices to ensure adherence to TCPA regulations. It’s a prime example of how ignoring compliance can create liabilities that snowball over time, eventually leading to staggering costs.

6. Keller Williams Realty 

Keller Williams Realty is facing a class action lawsuit filed by plaintiff Mark Ortega, who alleged receiving unsolicited telemarketing messages about a property listing. Despite being registered on the National Do Not Call Registry, Ortega claimed he received text messages promoting an open house sent by a Keller Williams realtor.

This case not only highlights violations of the federal TCPA but also underscores the need for compliance with state-specific DNC regulations, such as the Texas No-Call List. Real estate firms must remain vigilant to avoid liability by ensuring that outreach campaigns are thoroughly vetted for federal and state compliance. Failing to do so can result in penalties that impact individual agents and the broader company’s reputation.

Why 2025 Will Be a High-Risk Year for Businesses  

TCPA class action filings have already skyrocketed. Through October 2024, filings were up 21% compared to the previous year, which saw a 40% increase from the prior year. October 2024 alone marked the highest number of TCPA class actions ever filed. Businesses need to brace for even more activity in 2025, with the one-to-one consent rule expected to drive further litigation.

The Financial Risks Are Rising   

The stakes have never been higher. Class action lawsuits can result in settlements reaching millions of dollars, as cases like Citibank and Visalus demonstrate. Non-compliance isn’t just a financial risk; it damages a company’s reputation. This makes it harder to rebuild trust with consumers and partners. Organizations that fail to prepare for these changes may be overwhelmed by litigation, costly settlements, and negative media coverage.

Consumer Expectations Are Changing  

Modern consumers are increasingly aware of their rights and are less tolerant of invasive or unauthorized marketing practices. Businesses must adapt by implementing robust systems that respect consumer preferences and ensure clear, direct consent is obtained. Companies that fall short risk losing customer trust, which is critical for long-term success in today’s highly competitive landscape.

How Searchbug Can Help in TCPA Compliance 

Searchbug offers tools like the Phone Validator API, which checks phone numbers against Federal and State Do Not Call lists. Moreover, it also flags high-risk numbers with DNC complains and TCPA litigations. By leveraging this technology, businesses can stay compliant with the updated TCPA regulations and minimize risk.

Searchbug also offers FREE API Testing with $10 credits. This will allows businesses to test live data and see how the Phone Validator integrates into their workflow.

Other Benefits of Searchbug’s Phone Validation Tool:

• Time-Saving Automation: Automate your compliance checks, allowing your team to focus on other tasks.
• Accurate Risk Assessment: Identify and avoid high-risk numbers to reduce exposure to litigation.
• Scalability: Whether you’re a small business or a large enterprise, Searchbug’s solutions can scale with your needs.

Take Action Today   

The risks of TCPA non-compliance are escalating, and time is running out. Companies like Visalus, Citibank, and DoorDash have already faced the financial fallout of failing to adhere to these regulations. Don’t let your business be next.

With tools like Searchbug’s Phone Validator, you can shield your company from costly mistakes. Register for a FREE API Test Account today and take control of your telemarketing practices before it’s too late!