What is the statute of limitations for a TCPA claim?

Four years from each violating call, under 28 U.S.C. § 1658(a). It runs to the date suit is filed.

How long do I have to respond to a TCPA demand letter?

Whatever the letter says, commonly 14 to 30 days. It is the sender’s deadline, not a legal one. A written extension request before the date is usually granted.

How quickly must I honour a request to stop?

A revocation of consent must be honoured within ten business days under FCC rules effective April 2025. A company-specific do-not-call request must be recorded at the time and honoured within a reasonable time not exceeding 30 days.

How often do I need to scrub against the Do Not Call Registry?

Use a registry version no more than 31 days old for every campaign. Monthly downloads with logged dates are the standard practice.

When does the duty to preserve records start?

When litigation is reasonably anticipated. A demand letter is the usual trigger. From that date, relevant call, consent and vendor records must be kept.

index / 05 deadlines-and-clocks

Deadlines and clocks

Every clock that runs in a TCPA matter, grouped by whose clock it is: the claimant's, the caller's, the regulator's. The federal statute of limitations is four years from each call, under 28 U.S.C. § 1658(a). Each entry states when it starts, when it ends, and what happens at the end. Sources in each entry.

claimant clocks caller clocks letter clocks regulator clocks

Figures behind each clock: TCPA damages per call and every other number. State limitation periods and hours: state telemarketing laws table.

Claimant clocks

Four-year limitations period: Starts: each violating call or text. Ends: four years later. At the end: the claim for that call is time-barred. Measured to the filing of suit, not to a demand letter. Every call inside the window is claimable in one suit.src: 28 U.S.C. § 1658(a)
Twelve-month window (do-not-call): A private do-not-call claim requires more than one violating call by or on behalf of the same entity within any 12-month period. One call is a violation but not a private claim; the second within a year is.src: 47 U.S.C. § 227(c)(5)
Florida 15-day text notice: Starts: the recipient replies STOP to a text. Ends: 15 days later. At the end: any further text is actionable under the FTSA. Texts before the STOP are not independently actionable under the 2023 amendment.src: Fla. Stat. § 501.059 (2023)
State limitations periods: State claims take the state's period, which may be shorter than four years. Check the state statute or its general limitations provision.src: state law; varies

Caller clocks

31-day registry clock: Starts: a number is registered on the National Do Not Call Registry. Ends: 31 days later, when the number is protected. Separately, a seller's registry download must be no more than 31 days old when used. In practice: scrub every list against a fresh download at least monthly and log it.src: 47 C.F.R. § 64.1200(c)(2)(i)(D)
Ten business days to honour revocation: Starts: a consumer revokes consent by any reasonable means (STOP reply, request on a call, email). Ends: ten business days later. At the end: any further call or text is without consent. Effective 11 April 2025.src: 47 C.F.R. § 64.1200(a)(10); FCC 24-24
Reasonable time, not exceeding 30 days, for internal do-not-call requests: The longstanding outer limit for adding a person to the company-specific list after they ask. The request must be recorded at the time it is made.src: 47 C.F.R. § 64.1200(d)(3)
18 months and 3 months (established business relationship): An EBR from a purchase lasts 18 months from the transaction; from an inquiry, three months. It ends earlier if the person asks not to be called. It never covers prerecorded telemarketing.src: 47 C.F.R. § 64.1200(f)(5)
Daily calling window: 8am to 9pm, local time at the called party's location, for telephone solicitations. Florida and Oklahoma: 8am to 8pm. Set it in the dialer by the called number's time zone, not the office's.src: 47 C.F.R. § 64.1200(c)(1); Fla. Stat. § 501.059(4)
Three calls per 24 hours: Florida and Oklahoma cap on sales calls to the same person on the same subject.src: Fla. Stat. § 501.059(4); 15 O.S. § 775C.1 et seq.
Five-year retention: A company-specific do-not-call request must be kept for five years. Consent records are not given a fixed period by the rule; retaining them for at least the four-year limitations period is the practical minimum.src: 47 C.F.R. § 64.1200(d)(6)
Five seconds to release the line: An artificial or prerecorded voice system must release the called party's line within five seconds of the called party hanging up.src: 47 U.S.C. § 227(d)(3)(B)
Reassigned Numbers Database check: A caller that queries the database and receives a "no" (number not permanently disconnected since the date given) is protected by the safe harbour if the answer was wrong. The protection attaches to the query date; re-query before each campaign.src: 47 C.F.R. § 64.1200(m)

Demand letter clocks

Response deadline in the letter: Starts: the date on the letter or the date of receipt, as the letter states. Ends: the stated date, commonly 14 to 30 days. At the end: the sender's offer lapses and the matter is typically referred to litigation counsel. Not a legal limitation. Where the listed calls reconcile to the recipient's own records and no consent record exists, resolution before this date is ordinarily the lowest-cost outcome. Extensions are usually available on a written request made before the date.src: the letter itself
Notice for willfulness: Starts: receipt of the letter. From that point, calls to the listed numbers, and arguably to the same list with the same practice, are calls made with knowledge of the facts alleged. Stop contact on the day of receipt.src: 47 U.S.C. § 227(b)(3), (c)(5) (willful or knowing)
Preservation duty: Starts: when litigation is reasonably anticipated, which a demand letter establishes. No end until the matter is resolved. Deleting relevant records after this point can be sanctioned regardless of the merits.src: Fed. R. Civ. P. 37(e) and common law
Insurance notice: Starts: receipt of a claim. Ends: per policy, often "as soon as practicable". Late notice can forfeit cover that would otherwise exist. Many policies exclude TCPA claims; read the exclusions, then give notice if there is any prospect of cover.src: the policy

Regulator clocks

FCC forfeiture limitations: The TRACED Act lengthened the period within which the FCC may pursue forfeitures for certain intentional robocall violations to four years, from the general one-year period.src: TRACED Act, Pub. L. 116-105; 47 U.S.C. § 503(b)(6)
Hobbs Act review: A petition for review of an FCC order must be filed in a court of appeals within 60 days of the order's entry.src: 28 U.S.C. § 2344

Quick lookups

What is the statute of limitations for a TCPA claim?: Four years from each violating call, under 28 U.S.C. § 1658(a). It runs to the date suit is filed.
How long do I have to respond to a TCPA demand letter?: Whatever the letter says, commonly 14 to 30 days. It is the sender’s deadline, not a legal one. A written extension request before the date is usually granted.
How quickly must I honour a request to stop?: A revocation of consent must be honoured within ten business days under FCC rules effective April 2025. A company-specific do-not-call request must be recorded at the time and honoured within a reasonable time not exceeding 30 days.
How often do I need to scrub against the Do Not Call Registry?: Use a registry version no more than 31 days old for every campaign. Monthly downloads with logged dates are the standard practice.
When does the duty to preserve records start?: When litigation is reasonably anticipated. A demand letter is the usual trigger. From that date, relevant call, consent and vendor records must be kept.

updated: 2026-11-03 · status: general legal information, not legal advice · verify against the linked primary text before relying on any figure