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Pennsylvania Brings Marketing Texts Into Its Solicitation Rules

For marketing, CRM and CPaaS teams contacting Pennsylvania customers, the state’s amended telemarketing framework makes campaign classification and scheduling operational compliance issues. An October 19, 2026 state senator’s update announced implementation of Act 47, which expressly brings text messages into the telephone-solicitation framework. Covered campaigns face narrower contact hours and Sunday restrictions, but the statutory definition also contains important exclusions. Teams should determine whether each workflow is covered before changing promotional queues, account-notification routes or vendor instructions; a single statewide label is not a substitute for reviewing message purpose. ([senatorgeneyaw.com](https://www.senatorgeneyaw.com/enews/101926-2/))

Published:11/06/2026 Updated:11/06/2026

1. Regulatory focus

Act 47 expressly includes texts, voicemail and ringless voicemail within telephone solicitation, while prohibiting covered solicitations before 9 a.m., after 7 p.m., on Sundays and on legal holidays. The definition also excludes communications responding to qualifying prior express written consent, communications concerning an existing debt, contract, payment or performance, and contacts involving an established business relationship within the preceding 12 months. These exclusions are part of the coverage analysis, not optional campaign settings, so the hours restriction should not be presented as a blanket prohibition covering every business text sent to a Pennsylvania subscriber. ([palegis.us](https://www.palegis.us/statutes/unconsolidated/law-information/view-statute%26txtType%3DPDF%26SessYr%3D2026%26SessInd%3D0%26ActNum%3D0047.))

2. Business impact

Operationally, teams should separate promotional campaigns, sales-lead collection and contract-performance notifications rather than approving all traffic under one brand-level classification. Act 47 also updates registration provisions: covered telemarketers without an applicable exemption generally must register with the Pennsylvania Attorney General’s office at least 30 days before offering consumer goods or services for sale, and registration exemptions require their own assessment. A practical vendor review should therefore document registration status separately from message classification, with the responsible seller, campaign purpose and evidence for any exclusion attached to the workflow instead of treating technical route availability as regulatory clearance. ([palegis.us](https://www.palegis.us/legislation/bills/text/PDF/2025/0/SB0992/PN1649))

3. Operating recommendations

As an implementation recommendation, add a coverage-or-exclusion field to Pennsylvania workflows, pause unclassified marketing jobs, and configure covered campaigns and retries to stay within 9 a.m.–7 p.m. while blocking Sundays and legal holidays. Connect all seven statutory reply terms—STOP, QUIT, END, REVOKE, OPT OUT, CANCEL and UNSUBSCRIBE—to the suppression process rather than relying on a STOP-only integration. Use test numbers to check that an opt-out cancels queued promotional jobs, reaches each relevant vendor and produces a timestamped result; these controls are operational recommendations for implementing the statute, not additional requirements expressly prescribed by it. ([palegis.us](https://www.palegis.us/statutes/unconsolidated/law-information/view-statute%26txtType%3DPDF%26SessYr%3D2026%26SessInd%3D0%26ActNum%3D0047.))

Frequently Asked Questions

Can we send an evening delivery update for an existing order?
First check whether the text concerns performance of an existing contract, which the definition excludes. A notification label alone does not establish that exclusion. As a practical control, retain the order reference, triggering event and template version, and keep promotional offers out of the delivery update. If marketing content is added, reassess the complete message rather than automatically inheriting the transactional workflow’s classification. ([palegis.us](https://www.palegis.us/legislation/bills/text/PDF/2025/0/SB0992/PN1649))
Does an existing marketing opt-in automatically settle the scheduling question?
No. Review whether the agreement satisfies the statutory written-consent definition before relying on the exclusion. As an evidence package, collect the consent screen, seller identity, authorized telephone number, execution record and disclosure that consent is not a purchase condition. Have counsel assess the actual agreement; a practical interim approach is to retain the stricter campaign schedule when the supporting record is incomplete. ([palegis.us](https://www.palegis.us/legislation/bills/text/PDF/2025/0/SB0992/PN1649))
Our vendor already handles STOP. What else should we test?
Test the six other reply terms and verify the complete suppression path, not just the vendor’s conversation status. The state implementation update emphasizes stopping solicitation when requested. As an acceptance test, create duplicate promotional jobs across connected platforms, submit an opt-out and check cancellation results, CRM updates and retry logs. A feature screenshot does not demonstrate that every relevant outbound queue has actually stopped. ([senatorbaker.com](https://www.senatorbaker.com/enews/102026-2/?utm_source=openai))
This article is for informational purposes only and does not constitute legal advice.

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