One STOP Does Not Have to End Every Text You Send. In Klaviyo It Still Does

A customer replies STOP to a shipping update. What did they just leave?

On November 25, 2026 an amended 47 CFR 64.1200(a)(10) takes effect. The Federal Communications Commission published it in the Federal Register on October 26 as FCC 26-67, and it changes three things for a brand that texts its customers: what a STOP to an informational text revokes, whether a brand may name one exclusive way out, and what the confirmation text may say.

Klaviyo's help center, as it reads today, says a STOP removes consent for both transactional and promotional SMS, and that "your subscribers cannot opt out of only transactional or only promotional SMS". The rule and the stack we are asked to connect most often have just parted ways. This post reads both as written and ends on what to build before the date. Nothing here is legal advice.

What does the rule say from November 25?

The sentence that matters for a shipping or refill text: "Callers may interpret a revocation request made in response to an informational call or text message (i.e., a call or text message that does not contain any advertising or telemarketing) as applying only to the specific category of informational robocalls and text messages to which the revocation was directed and not to all communications."

The sentence that matters for a promotion: "Revocation requests made in response to calls or text messages that contain an advertisement or constitute telemarketing revoke consent to all future calls or text messages containing an advertisement or constitute telemarketing from that caller."

Read the verbs. The first is "may interpret", a permission. The second is "revoke", a result. A STOP to a sale announcement ends every marketing text from you. A STOP to a delivery notice can be read as ending delivery notices. The order says so directly: "We emphasize that this specific modification affects only informational robocalls." It does not say what a STOP to a marketing text does to the order updates the same customer consented to. We are not going to guess, and in Klaviyo you do not have to, because its STOP removes both.

Did the all or nothing rule ever apply to you?

The FCC's 2024 consent order adopted the original paragraph (a)(10), under which a revocation meant "the caller may not send additional robocalls and robotexts", effective April 11, 2025. Four days before that date the Consumer and Governmental Affairs Bureau granted "a limited waiver delaying the effective date of section 64.1200(a)(10)" to the extent it required a revocation made in response to one type of message to apply "to all future robocalls and robotexts from that caller on unrelated matters", until April 11, 2026. On January 6, 2026 the Bureau extended that waiver to January 31, 2027. The October order says its amendment "will go into effect at that time and supersede the delayed effective date".

What did take effect on April 11, 2025, and still stands: the seven standardized words, "stop," "quit," "end," "revoke," "opt out," "cancel," or "unsubscribe"; the duty to honor a revocation "within a reasonable time not to exceed ten business days from receipt"; and the confirmation text. Klaviyo's own page on that date lists the seven words and tells you to "Honor unsubscribe requests made by consumers via telephone call or sent to a brand's email address."

Can "Reply STOP" now be the only way out?

Yes, if you say so in every message. The amended paragraph opens: "Callers may designate any of the following methods as the exclusive means to revoke consent". For a text sender the method is "replying to an incoming text message with any one of the following standardized words", or "a website or telephone number designated by the caller to process opt-out requests". The condition: "The caller must clearly and conspicuously disclose the designated method to revoke consent on the call or in the text."

A text sender satisfies it by including at least one of the seven words "in each text message so long as the text sender recognizes the use of any of the standardized words as a valid revocation request." A caller that designates "is not required to process revocation requests made by any other means." The new paragraph (a)(11) covers everyone else: "Callers that do not designate an exclusive means to revoke consent pursuant to paragraph (a)(10) of this section must process revocation requests made by any reasonable means." Both paragraphs carry the ten business day limit.

Two build consequences follow. The disclosure has to be in each text, shipping and refill flows included, not only the welcome message. Klaviyo's default unsubscribe instructions read "Text STOP to opt-out", take 20 characters by default, and "are always toggled on by default for every SMS campaign and flow message", but they can be turned off per message on numbers that receive replies. A flow message trimmed to save characters carries no disclosure, and the designation does not reach it.

And if you designate nothing, your support inbox is still a door. A customer who emails asking you to stop texting has revoked by a reasonable means, the ten day clock started when the email arrived, and your SMS platform has no idea. Klaviyo says you "have the ability to manually remove consent at any time, such as if someone requests an unsubscribe without a keyword", and that "It is ultimately your responsibility to comply with the FCC's regulations." The build item is the handoff: a support macro that removes SMS consent on the profile and records the date the request was received.

Why does a subscription brand have a "cancel" problem?

"Cancel" is one of the seven words. Klaviyo's keyword setting defaults to "Contains word", under which "if someone texts 'Cancel subscription,' this removes SMS consent", recommended for "those who want to remain strictly compliant". The alternative, "Exact match", is "Recommended for: subscription businesses for words like 'cancel,' 'unsubscribe,' 'end,' and 'quit.'", because "Customers may send these when discussing the subscription itself rather than their SMS consent."

So a customer who texts cancel about next month's box has done one of three things. Asked for customer service. Sent a per se opt-out word, which under the default setting removes their SMS consent and triggers a confirmation that "always uses the word 'stop,' regardless of which opt-out keyword was used". And, if you let customers cancel a subscription by text, made a cancellation request that the New York City and Connecticut rules now govern. The amended rule does not say whether a sentence containing one of the seven words is a reply "with" that word. Pick a setting with counsel, write down why, and give support a script for the texts that land in between.

What happens in Klaviyo when someone texts STOP?

Klaviyo offers keyword instructions on numbers that receive replies and an unsubscribe link on numbers that cannot, and the consequence is the same for both: "When a customer unsubscribes via either option, it automatically removes consent for both transactional and promotional SMS."

The granularity the FCC just allowed exists in Klaviyo for a human and not for a keyword. On a single profile, "If the profile has separate SMS transactional consent, removing marketing consent does not stop those transactional texts", and the profile view has a separate Unsubscribe for "Text messaging marketing" and "Text messaging transactional". A STOP does not use that path.

For a subscription brand that is the whole story in one line: after a STOP to a promotion, the shipped and refill texts stop too. The FCC's reasoning describes that customer exactly: "consumers may not even be aware that by revoking consent with respect to one category of informational messages, they are revoking consent to all messages from that caller." Nothing in the rule requires Klaviyo to change this; a caller "may" read a STOP narrowly, and all or nothing is the conservative reading. What it costs you is the order update the customer still wanted, so say in the disclosure where you collect consent that STOP ends every text, order updates included. The confirmation that could have said it cannot be edited.

What about the confirmation text?

The paragraph that takes effect on November 25 is shorter than the one it replaces. The current text calls the confirmation "a one-time text message", requires that it "is the only additional message sent to the called party after receipt of the revocation request", and lets a sender that sends several categories of texts "request clarification as to whether the revocation request was meant to encompass all such messages". None of those three appears in the amended paragraph (a)(12). What survives: a confirming text "does not violate" the rule "as long as the confirmation text merely confirms the text recipient's revocation request and does not include any marketing or promotional information", and "If the confirmation text is sent within five minutes of receipt, it will be presumed to fall within the consumer's prior express consent."

The order's only explanation is footnote 30, which says paragraphs (10), (11) and (12) were amended "accordingly to reflect this modification", the category change. Its Further Notice asks for comment on a request from Vibes Media "that text senders be allowed to request clarification of the category of message from which the consumer intended to revoke consent in a confirmation text message." Until that is settled, the safe build is the one that was always safe: one confirmation, within five minutes, nothing promotional in it. Klaviyo's automatic response is that message.

Does any of this reach your texts at all?

Paragraph (a)(10) applies to texts "made pursuant to paragraphs (a)(1) through (3) and (c)(2)". The first three turn on an automatic telephone dialing system or an artificial or prerecorded voice; (c)(2) is the national do-not-call registry. The Supreme Court held in Facebook v. Duguid in 2021 that "To qualify as an 'automatic telephone dialing system' under the TCPA, a device must have the capacity either to store a telephone number using a random or sequential number generator, or to produce a telephone number using a random or sequential number generator." Whether your sending platform meets that definition is for counsel. Build as if it does: Klaviyo's keyword handling and confirmation text run either way, and its compliance basics say to "Always include a way for subscribers to opt out of your SMS campaign and flow messages."

What to do before November 25

1. Decide, with counsel, whether to designate "Reply STOP" as the exclusive means. If yes, the opt-out instructions stay on in every campaign and flow message, transactional flows included, and you still honor all seven words.
2. If no, write the inbox handoff. Any reasonable request counts, the ten business days run from receipt, and someone removes consent on the profile by hand.
3. Choose "Contains word" or "Exact match" for cancel, end, quit and unsubscribe, and give support a script for the texts that are really about the box.
4. Put the all or nothing consequence in the consent disclosure, because a STOP in Klaviyo ends the order updates too and the confirmation cannot say so.
5. Log every revocation with the date received and the channel. The clock and the proof both start there.

If the SMS program, the subscription app and the support desk were set up by three different people, this is the seam a CPG and ecommerce build is meant to close. It sits next to the subscription checkout wording Shopify reset in June: the same customer, three systems, and no one system that sees the whole conversation.

Common questions

Sources

• Federal Register, 91 FR 67214, Enhancing the Ability of Consumers To Control the Robocalls, FCC 26-67, final rule published October 26, 2026, effective November 25, 2026, including the amended text of 47 CFR 64.1200(a)(10) through (12) checked 2026-11-04
• FCC 26-67, Report and Order and Further Notice of Proposed Rulemaking, CG Docket No. 02-278, adopted September 30, 2026, released October 1, 2026, full text with Appendix A checked 2026-11-04
• 47 CFR 64.1200, Delivery restrictions, current text at eCFR before the November 25, 2026 amendment checked 2026-11-04
• FCC 24-24, Report and Order and Further Notice of Proposed Rulemaking, CG Docket No. 02-278, released February 16, 2024, the TCPA Consent Order checked 2026-11-04
• DA 25-312, Order granting a limited waiver of section 64.1200(a)(10) until April 11, 2026, Consumer and Governmental Affairs Bureau, April 7, 2025 checked 2026-11-04
• DA 26-12, Order extending the waiver of section 64.1200(a)(10) until January 31, 2027, Consumer and Governmental Affairs Bureau, January 6, 2026 checked 2026-11-04
• Facebook, Inc. v. Duguid, No. 19-511, Supreme Court of the United States, decided April 1, 2021, syllabus checked 2026-11-04
• Klaviyo Help Center, Understanding the opt-out options for an SMS message, updated November 4, 2025 checked 2026-11-04
• Klaviyo Help Center, April 11 SMS opt-out compliance change, updated July 7, 2025 checked 2026-11-04
• Klaviyo Help Center, How to configure your opt-out keyword settings, updated August 6, 2025 checked 2026-11-04
• Klaviyo Help Center, How to remove SMS consent from a single profile, updated October 27, 2025 checked 2026-11-04
• Klaviyo Help Center, Basics, SMS compliance, updated October 28, 2025 checked 2026-11-04

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