The Federal Communications Commission (FCC) has further extended the effective date of the Revoke All consent rule from April 11, 2026 to January 31, 2027. That rule requires businesses to treat a consumer's consent revocation request made in response to one type of text message or call as applicable to all future calls and texts from that caller on all other matters. The FCC first extended the effective date last April.
The FCC's new extension is intended to allow more time for the FCC to take comments and consider adjustments to the rule. In particular, the FCC recently initiated a rulemaking proceeding to seek comment on ways the agency can modify the requirement that a caller must treat an opt-out request made in response to one type of call or text to be an opt-out request for all types of calls and texts. Reply comments in that proceeding are due on February 3, 2026; please let us know if you would like to prepare and file comments.
The FCC considers outbound texts to constitute "calls" under its rules, although courts are beginning to push back on that interpretation. The FCC notes that it might also modify this requirement.
Note that the extension applies only to the Revoke All consent rule and does not impact the other consent revocation requirements, including:
- Maintaining reasonable consent revocation methods
- Providing alternative ways to revoke consent (including STOP, QUIT, END, REVOKE, OPT-OUT, CANCEL, and UNSUBSCRIBE—although the FCC and class action plaintiffs' attorneys will likely expect companies to designate other keywords as revocation requests)
- Not prescribing exclusive opt-out methods consumers must use to revoke consent
- Disclosing in a text message that the system is not capable of accepting all or some responses that revoke consent
- Honoring all opt-out requests no later than ten business days after the request
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