Reference

Quiet Hours: The 8am–9pm Rule

TCPA quiet hours limit marketing texts to 8am–9pm in the recipient's local time. Since late 2024 a wave of class actions has targeted sends outside that window — even where the recipient consented. Here's the rule, the live litigation, and how to stay clear.

reference Last verified mid-2026 2 min read

Quiet hours are a TCPA restriction: telemarketing calls and texts may not be sent before 8:00am or after 9:00pm in the recipient’s local time (47 CFR 64.1200(c)(1)). It applies to solicitation/marketing messages — and it is currently the most active litigation front in SMS compliance.

The rule

  • Allowed window: 8:00am–9:00pm in the recipient’s local time — not the sender’s, not the server’s.
  • Applies to: marketing / solicitation texts.
  • Different treatment: transactional and informational messages the recipient specifically requested (order updates, OTPs, appointment reminders) are treated differently and are not the target of these claims.

The local-time requirement is the trap: a 9:30pm Eastern blast is already past quiet hours for your East-Coast recipients even though it’s only 6:30pm on the West Coast.

The post-November-2024 class-action wave

Consent does not (yet) shield you
Since November 2024, 100+ cookie-cutter class actions have alleged that marketing texts sent outside the 8am–9pm window violate the TCPA — even where the recipient consented. The plaintiffs’ theory is that quiet-hours liability is independent of consent. This is unsettled, but it is being actively litigated, and the cost of being a test case is high given the per-message statutory damages.

The pending FCC petition

The industry is pushing back. The Ecommerce Innovation Alliance filed an FCC petition on March 3, 2025, arguing that PEWC forecloses quiet-hours liability — i.e. that a consumer who gave written consent can’t then sue over the send time.

  • Comments closed April 10, 2025.
  • The petition is still pending / unresolved as of mid-2026. Last verified mid-2026

Until the FCC rules, the safe assumption is that quiet hours apply regardless of consent.

Practical guidance

  1. Send marketing texts only 8am–9pm in the recipient’s local time. Use the recipient’s known address, or their area code as a proxy, to determine local time.
  2. Default to the recipient’s most likely time zone when you only have an area code, and bias conservative near the window edges.
  3. Don’t rely on consent as a quiet-hours defense while the petition is pending.
  4. Separate transactional from marketing sends — transactional messages the user requested aren’t subject to the same window, but don’t smuggle marketing into them.

Check whether a planned send time is inside the window for a given area code with the Quiet-Hours Helper.

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