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If your business contacts consumers by phone or text, 2025 delivered a clear and costly warning: TCPA litigation didn’t just tick upward — it exploded. For companies operating in the insurance, healthcare, financial services, and telemarketing space, understanding this shift isn’t optional. It’s the difference between a compliant operation and a lawsuit waiting to happen.

2,628
TCPA lawsuits filed in 2025		 60%
Increase over 2024		 10 days
New FTC opt-out window		 +37%
FCRA filings YoY

The Numbers Tell the Story

According to CompliancePoint’s TCPA Litigation Trends 2025 Year in Review report, a staggering 2,628 TCPA lawsuits were filed in 2025 — a 60% increase compared to 2024. That surge represents what the report describes as “unprecedented compliance challenges and risk for telemarketing operations.”

This finding is independently corroborated. WebRecon data, reported by the Consumer Financial Services Law Monitor, confirms that TCPA filings rose year-over-year throughout all of 2025. Broader consumer protection litigation is surging in parallel — FCRA filings climbed 37.4%, FDCPA filings rose 7.8%, and CFPB complaint channels jumped 89.1%. The TCPA spike is part of a much larger wave, and it isn’t slowing down.

Why TCPA Litigation Is Rising: Key Drivers in 2025

Several converging forces drove the 2025 lawsuit surge. Compliance teams need to understand each one to build an adequate response.

Serial Plaintiff Activity Is Intensifying

Professional plaintiffs and their law firms are systematically targeting businesses with well-organized litigation strategies. The CompliancePoint report highlights serial plaintiff patterns as a central risk factor, identifying the most active plaintiff law firms and the states generating the highest lawsuit volumes. If your industry or geography appears in those high-risk columns, your current compliance posture deserves immediate scrutiny.

Time-of-Day Restrictions: A New Litigation Frontier

A notable wave of 2025 lawsuits was premised on 47 CFR Section 64.1200(c)(1), which bars certain solicitations before 8 a.m. and after 9 p.m. local time. Plaintiffs filed claims even against companies that had consent and existing business relationships — arguing that consumers never explicitly authorized contact at specific times of day. Courts are still working through the consent standard, and the FCC has a petition pending. Companies must monitor this area closely.

The Text Message Classification Question Remains Unsettled

Whether text messages qualify as “calls” under key TCPA provisions resurfaced as a central legal question in 2025. Courts issued varying and sometimes conflicting decisions throughout the year. Companies using SMS or text-based outreach should be actively working with legal counsel to track these developments, as the wrong assumption here can trigger significant liability.

State “Mini-TCPAs” Are Expanding the Compliance Map

Federal TCPA exposure is only part of the picture. States are actively passing their own telemarketing laws. Texas significantly expanded its mini-TCPA in 2025, adding a business registration requirement and broadening the scope of covered solicitations. While a federal court order provided some relief on consented texts, that decision is not nationally binding. Companies operating in multiple states need state-by-state compliance programs — not a single federal TCPA policy — to adequately manage risk.

Opt-Out Processing Timelines Got Tighter

⚠ FTC Rule Update: The FTC’s revised Telemarketing Rule reduced the time businesses have to process consumer opt-out requests from 30 days to just 10 days. The rule also expanded what qualifies as a “reasonable” revocation request. For companies managing large contact lists, this is an operational challenge — not just a policy update.

Companies should validate immediately that their CRM, marketing automation, and call center systems can reliably honor opt-out requests within the new 10-day window. Systems built around the prior 30-day standard are now non-compliant on day 11.

Industries and Geographies in the Crosshairs

CompliancePoint’s report breaks down which industries are most frequently targeted by TCPA plaintiffs and which states are generating the highest lawsuit volumes. This data is invaluable for risk-tiering your compliance investments. Health insurance, financial services, and home services companies consistently appear at the top — but any business conducting outbound consumer contact by phone or text carries exposure.

How TLD CRM Stays Ahead of the Compliance Curve

At TLD CRM, TCPA compliance isn’t a checkbox — it’s embedded into how our platform is built and how we support our clients. As a CRM and telephony infrastructure provider serving health and life insurance agencies in both the ACA and Medicare markets, we operate in one of the most heavily regulated contact environments in the country. That context shapes everything we do.

Our compliance team actively monitors regulatory developments from the FCC, FTC, and state legislatures — including the Texas SB140 expansion, FTC opt-out rule changes, and evolving FCC rulemaking on consent standards. When the compliance landscape shifts, we work to make sure our clients have the information and tools they need to adapt.

Practically, this means:

✓Tracking TCPA and telemarketing rule changes in real time and communicating updates to our client base
✓Designing platform workflows that support documented consent capture and opt-out management at scale
✓Monitoring developments in SMS classification, reassigned numbers, and time-of-day compliance that directly affect outbound dialing operations
✓Engaging legal and compliance experts to inform our product roadmap and client guidance — not just our internal policies
✓Publishing ongoing compliance content so agencies using our platform can stay informed without tracking every regulatory docket themselves

We believe the best compliance program isn’t one that reacts to lawsuits — it’s one that prevents them. TLD CRM is committed to being a platform our clients can trust to help them operate compliantly in an increasingly complex regulatory environment.

What Businesses Should Do Right Now

The combination of a 60% lawsuit surge, expanding state laws, new FCC rulemaking activity, and a 10-day opt-out window makes 2025’s TCPA environment one that demands a proactive, not reactive, compliance strategy. Focus on these six areas immediately:

✓Audit your consent mechanisms. Given the time-of-day litigation trend and evolving court decisions on consent standards, consent language and capture processes need to be reviewed for specificity and legal adequacy — not just general TCPA compliance.
✓Review your contact data sources. Serial plaintiff activity often exploits stale, purchased, or improperly sourced contact lists. Clean, well-documented data provenance is a meaningful defense.
✓Start using the FCC’s reassigned numbers database. The database exists specifically to help companies avoid calling people who inherited a number from a consenting individual. Not using it is an avoidable risk.
✓Update opt-out workflows for the new 10-day window. Validate that your CRM, marketing automation, and call center systems can honor requests within the new timeframe. Systems built around 30 days are now out of compliance.
✓Map your state-level exposure. If you’re doing business in Texas or other states with active mini-TCPA legislation, you need state-specific compliance protocols. Treat state telemarketing law as a living document.
✓Evaluate arbitration clauses and class action waivers. These provisions in consumer-facing agreements remain one of the most effective structural defenses against high-stakes TCPA class actions. Review yours with counsel.

The Bottom Line

The 2025 TCPA litigation surge isn’t an anomaly. It’s the result of a growing and organized plaintiff bar, expanding regulatory requirements at both the federal and state level, and an increasingly aggressive enforcement environment. The question isn’t whether TCPA exposure is real — the data makes clear that it is. The question is whether your compliance program is built to meet the moment.

For agencies and businesses operating in the ACA and Medicare insurance markets, where phone and text outreach is core to sales operations, the stakes are especially high. Compliance isn’t a burden — it’s a business asset that protects your operations, your clients, and your reputation.

Built for Compliant Insurance Operations

TLD CRM provides CRM and telephony infrastructure designed for health and life insurance agencies navigating complex regulatory environments. Learn how our platform supports compliant outreach at scale.

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