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On January 6, 2026, the FCC extended its waiver of 2024 rules requiring businesses to honor consent revocation requests uniformly across different brands and, in certain cases, call types (i.e., marketing vs. transactional). In April 2025, the Commission had granted a one-year waiver in response to an industry petition, but, four months before its expiration, the FCC extended once again, this time until January 31, 2027.
As previously discussed, the rule posed significant compliance challenges for telemarketers. Acknowledging its operational complexity, the FCC sought further comment in October 2025 on ways it could modify the requirement. The FCC notes this extension comes in response to requests from several organizations to "further extend the effective date to allow an opportunity to revisit this issue."
At this juncture, one can fairly question whether this rule will ever take effect; at minimum, revisions are likely. This prolonged process reflects a tension between this administration's deregulatory, business-friendly posture and ongoing efforts to curb robocalls and texts – one of the few remaining areas with some bipartisan consensus.
During this extended waiver period, telemarketers may continue to apply consent revocation on a brand- or call-type-specific basis under existing rules. As a reminder, this delay applies only to this specific provision. Other requirements under the 2024 Order, including the shortened timeframe for honoring opt outs and the confirmation message obligation, remain in effect.
The FCC's reconsideration may eventually lead to a uniform revocation requirement in some form. As a result, businesses should ensure they have governance and infrastructure in place to adapt quickly if a modified rule is finalized.
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