The FCC issued an Order today which partially delays implementation of its new rules governing consumers’ revocation of consent to receive robocalls and robotexts under the Telephone Consumer Protection Act (TCPA).
The delay responds to concerns from banks, financial institutions, and other large organizations about the complexity of compliance. Additionally, this issue is the subject of a current rulemaking on which the FCC solicited and is receiving comments. The Order now further extends the effective date of that part of the of the rule that requires that any reasonable revocation of consent (e.g., replying “STOP” to one text) would revoke all consent for all robocalls and robotexts from that caller across all business units and purposes. The new effective date is January 31, 2027. All other components of the Revocation of Consent Rule remain in effective, namely provisions requiring that:
- consumers may revoke consent using any reasonable method;
- Certain revocation methods (like “STOP”) are per se reasonable; and
- Callers must honor revocations promptly.
Again, the only component of the rule that is affected by the Order is the requirement that the revocation apply across all business units and for all purposes. The revocation will still apply to related messages from the business unit that transmitted the call or message.
A copy of the FCC Order is available here.
Mitchell Roth
