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How long a TCPA business relationship lets a dealership keep calling or texting a customer.

BY CARBIDE DIGITALPUBLISHED September 13, 2026REVIEWED September 13, 20267 min read525 WORDS

A dealership calling or texting a past customer relies on a TCPA business relationship exemption that has real time limits, and, as of 2025, a materially faster opt-out requirement than before. Two separate misconceptions sit inside this: how long the exemption lasts, and how quickly an opt-out request has to be honored across every channel.

ANSWER IN BRIEF

TCPA Business Relationship Rules for Dealership Marketing

Two separate rules govern dealership follow-up calling and texting under the federal Telephone Consumer Protection Act (TCPA). First, the established business relationship exemption allows continued contact with a past customer, but on a defined clock: roughly eighteen months from the customer's last purchase, delivery or payment for a transaction-based relationship, or roughly three months from a mere inquiry that never became a sale, and calls made using an autodialer are not covered by this exemption at all, meaning ordinary consent rules still apply to them regardless of the relationship. Second, as of an FCC rule effective April 2025, a business must accept an opt-out request through any reasonable method, not only a reply of 'STOP,' and must stop all promotional messages within ten business days of receiving it, down from the previous thirty-day standard. A dealership's marketing automation can honor the letter of one of these rules and still violate the other.

Reviewed September 13, 2026 by Carbide Digital

KEY TAKEAWAYS

The short version.

The established business relationship exemption runs roughly 18 months from a customer's last purchase, delivery or payment, or roughly 3 months from a mere inquiry that never became a sale.
Calls placed with an autodialer are not covered by the existing-relationship exemption at all; ordinary consent rules apply to those regardless of the relationship's age.
The National Do Not Call Registry and any individual opt-out request must be honored even during an active existing-business-relationship window.
As of an FCC rule effective April 2025, an opt-out must be accepted through any reasonable method, not just a 'STOP' reply, and honored within 10 business days, down from the prior 30-day standard.

#The TCPA business relationship clock most dealerships don't track

The relationship most dealership follow-up marketing relies on is the transaction-based version: a customer who bought, took delivery of, or made a payment on a vehicle. That relationship supports continued contact for roughly eighteen months from the most recent qualifying event, and a new purchase or payment resets the clock from that new date rather than extending the original one indefinitely.

A narrower version covers a customer who only inquired, requested a quote, or applied for financing without completing a purchase. That relationship supports contact for roughly three months from the inquiry, a materially shorter window that a marketing calendar built around the eighteen-month figure will overrun without anyone noticing.

Neither version of the exemption covers calls placed with an automatic telephone dialing system. If a dealership's follow-up calling uses an autodialer, ordinary TCPA consent requirements apply regardless of how recent or well-documented the customer relationship is.

#How the TCPA business relationship opt-out rule changed for dealerships in 2025

The opt-out standard got stricter. Under an FCC rule effective April 2025, a business receiving a request to stop texts or calls must honor it if it arrives through any reasonable method, a reply of 'STOP' being only one example, not the only valid one. A request made by email, a phone call, a website form, or even a spoken request during a live call now counts, which is a meaningfully broader standard than treating only a specific keyword reply as valid.

The compliance window for acting on that request was shortened from thirty days to ten business days. A single confirmation message, sent within about five minutes and containing no promotional content, is permitted to clarify what the customer wants stopped, but no further promotional messages may go out after the opt-out is received.

A fragmented marketing stack creates a specific risk here. A CRM sending service reminders, a separate platform sending sales follow-up, a third handling review requests: an opt-out honored in one system does not automatically propagate to the others unless someone specifically connected them.

TABLE

The two rules side by side

A summary for orientation; the applicable facts of a specific programme should be reviewed with your attorney.

Rule	What it covers	Key figure
Transaction EBR	Contact following a completed purchase, delivery or payment	~18 months from the last qualifying event
Inquiry EBR	Contact following an inquiry that did not become a sale	~3 months from the inquiry
Autodialer carve-out	Calls placed with an automatic dialing system	EBR exemption does not apply; ordinary consent rules do
Opt-out method	How a customer can request to stop	Any reasonable method, not only a 'STOP' reply, as of April 2025
Opt-out compliance window	How fast the business must stop	10 business days, down from 30, as of April 2025

Compiled 2026-09-13 from public summaries of the TCPA established-business-relationship exemption and the FCC's April 2025 opt-out rule; not a substitute for a legal review of a specific programme.

How this fits inside a broader database and lapsed-customer outreach plan is covered on the automotive marketing hub.

This is one of Carbide’s insights on dealership marketing and SEO.

DIRECT ANSWERS

Questions about this topic.

How long can we keep calling a past customer?

About 18 months. Roughly 18 months from their last purchase, delivery or payment for a transaction-based relationship, or roughly 3 months from a mere inquiry that never became a sale. A new transaction resets the clock from that new date.

Does the existing-relationship exemption cover autodialed calls?

No. Calls placed with an automatic telephone dialing system are not covered by the existing-business-relationship exemption at all, so ordinary consent requirements apply regardless of relationship history.

Do we still have to honor Do Not Call requests during an active relationship window?

Yes, always. The National Do Not Call Registry and any individual opt-out request must be honored even while an existing-business-relationship exemption would otherwise apply.

Is 'reply STOP to opt out' still sufficient?

Not the only one anymore. It is one valid method but no longer the only one that must be honored. As of an FCC rule effective April 2025, any reasonable method of requesting to stop, by phone, email, form or spoken request, must be accepted.

How fast do we have to stop messaging after an opt-out?

Ten business days, not thirty. Down from the prior 30-day standard, as of the same April 2025 rule. A single non-promotional confirmation message is permitted within about five minutes to clarify scope.

What if our CRM, sales platform and review-request tool are all separate?

Usually not, unfortunately. An opt-out honored in one system does not automatically apply to the others unless someone specifically connected them, which is a common gap worth reviewing with whoever manages your marketing stack.

Does this apply to email as well?

No. The TCPA governs calls and texts. Email marketing runs under a separate federal framework (the CAN-SPAM Act), with its own opt-out and disclosure rules, so a TCPA-compliant calling programme does not automatically make an email programme compliant.

A customer only inquired about a trade-in and never bought. Which clock applies?

The shorter one. An inquiry that never became a sale or a service visit falls under the roughly three-month exemption window, not the roughly eighteen-month window that applies to a completed purchase, delivery or payment.

Does an opt-out from one purchase carry over to a future purchase at the same store?

Generally treated as a standing preference rather than tied to one transaction, but how a specific CRM or platform records and applies an opt-out is implementation-specific, so confirming the behavior with whoever manages that system is worth doing rather than assuming.

PRIMARY SOURCES

References used for this analysis.

Federal Communications Commission: Telephone Consumer Protection Act rules

Continue the analysis.

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