On Sept. 30, the Federal Communications Commission adopted new rules for how callers handle requests to stop automated calls and texts. The change reaches collection agencies and the finance teams that hire them.
Under the order, a caller can treat an opt-out from an informational message as covering only that category of message. A consumer who replies STOP to a past-due text would not automatically lose fraud alerts or account notices.Â
Telemarketing works differently. An opt-out there still stops all future telemarketing calls and texts from that caller. Callers can also designate one disclosed method for revoking consent, such as a key press during a call, a reply text or a dedicated website or phone line.
For the people who work delinquent business accounts, the vote came during a shift already under way.
How the TCPA Rules Are Changing
The Telephone Consumer Protection Act (TCPA) has governed automated calling since 1991, and its reach has grown. In February 2024 the FCC ruled that AI-generated voices count as “artificial” under the law, so automated voice calls need the same prior consent as a traditional robocall.
Opt-outs followed. Since April 2025, callers have had 10 business days to honor a revocation a consumer makes through any reasonable means. A 2024 order would also have extended each revocation to all of a caller’s automated calls and texts starting Jan. 31, 2027. The Sept. 30 order replaces that approach for informational messages. The new rules take effect 30 days after the order appears in the Federal Register.
The FCC also opened comments on further changes. Its proposals include cutting the 10-business-day window to seven, requiring one-way text programs to accept reply opt-outs and requiring callers that use category-based opt-outs to also offer a revoke-all option. The notice also covers how revocations apply across affiliates.
In McLaughlin Chiropractic v. McKesson, decided in June 2025, the Supreme Court held that district courts are not bound by the FCC’s reading of the statute, adding another layer of uncertainty as the rules develop through agency action and litigation.
Collection Agencies Are Using More Data Before Outreach
Collectors have answered by putting more analysis in front of the call. In TransUnion’s 2026 industry report, 93% of collection firms said they use or plan to use AI or machine learning.
Compliance monitoring and communication support topped the list of uses, and scoring and treatment strategies followed at 45%. That survey leans toward consumer collections, but commercial agencies use scoring too.
The finance side is moving the same way, if only more slowly. Gartner found that 59% of finance functions used AI in 2025, roughly flat from a year earlier. For a controller placing aged receivables, the issue is less about whether an agency uses software than what the software decides. Approaching a high-balance account with a verified accounts payable contact and a small balance tied to a disconnected number should not start the same way, and a scored file makes that difference visible.
Business Contacts Can Change Before Invoices Are Paid
Commercial accounts bring a data problem of their own where the employee who approved the original purchase may leave before the invoice is paid.
The Bureau of Labor Statistics put median tenure with a current employer at 4.1 years in January 2026, and 20.6% of workers had been in their jobs a year or less.
Email addresses turn over too. ZeroBounce’s 2026 Email List Decay Report found that about 23% of the addresses it analyzed went bad in 2025.
A call to the wrong person costs time and under a tightening consent regime, it can also carry risk.
What Happens Before a Commercial Collection Call is Made
Some agencies now publish what that pre-contact work involves. Southwest Recovery Services, a commercial collection agency founded in 2004, has set out a four-stage sequence each placed account passes through. It describes the sequence as predictive scoring in commercial collections.
| Stage | What happens |
|---|---|
| Placement | Creditor submits the debtor company, balance, invoices and prior contact history |
| Account assessment | Missing data is filled and the account is screened against applicable rules |
| Scoring and contact verification | Account is scored for contact probability; skip tracing confirms decision-makers |
| Sequenced outreach | Contact is ordered by timing, channel and balance size |
Work begins within one business day of placement, according to the firm. The platforms involved include third-party systems. Experian supplies data, while TCN provides predictive dialing and Skit.ai offers voice automation. The firm determines the order.
“In a slower-paying market, the first contact on a commercial account carries more weight. We built our own sequence for scoring and routing each account on two decades of recovery data, and it decides which accounts we work first and how we reach them,” said Steven Dietz, CEO & Founder of Southwest Recovery Services.
The Fair Debt Collection Practices Act covers consumer debts. For commercial accounts, the firm says it applies the rules that govern business collections at the data layer and follows the TCPA for phone contacts.Â
Agencies that planned around the Jan. 31, 2027 date now have less time to get ready. Category-based opt-outs also add a field to every contact record: the kinds of messages each person has stopped. For agencies that verify contacts and channels during scoring, that becomes one more item in the account file.
People also ask
What is predictive scoring in debt collection? It is a method of estimating how likely each placed account is to result in contact, so an agency knows where to start. TransUnion’s 2026 industry report found 45% of collection firms use AI for scoring and treatment strategies.
Why is skip tracing important on a commercial account? Skip tracing confirms who can approve payment today. Median job tenure was 4.1 years in January 2026, and about one in five workers had been in their job a year or less, so the original contact on a commercial account may have left.
What did the FCC approve on Sept. 30, 2026? The FCC approved changes allowing callers to treat an opt-out from an informational robocall or text as applying only to that category of communication and to designate an exclusive method for revoking consent. The order replaces the broader “revoke all” approach that had been scheduled to take effect on Jan. 31, 2027.
