- within Media, Telecoms, IT and Entertainment topic(s)
- within Technology and Compliance topic(s)
The Federal Communications Commission ("FCC") issued an Order on January 6, 2026, to extend the effective date of its "Revoke All" consent rule from April 11, 2026, to January 31, 2027. This marks the second extension of these rules, which were initially scheduled to take effect on April 11, 2025.
The FCC based its extension on its need to review the record in its recent Further Notice of Proposed Rulemaking ("FNPRM" or "Caller Identification and TCPA Modernization FNPRM"), which seeks comment on the Revoke All consent rule as well as caller identification requirements. The FCC also reasoned that it is in the public interest to prevent industry from making unnecessary and costly operational changes before any rule changes are finalized.
What is the Revoke All Consent Rule?
The Revoke All consent rule (47 CFR § 64.1200(a)(10)) requires businesses to treat a consent revocation request made in response to one type of informational message as applicable to all future robocalls and robotexts from that caller on unrelated matters. Since the agency adopted this rule in its 2024 Strengthening the Ability of Consumers to Stop Robocalls Report and Order, various industry groups and organizations expressed concern that this rule could inadvertently prevent consumers from receiving wanted communications (e.g., doctor's appointment reminders) when they only intended to stop marketing calls.
What Remains Effective?
Notably, the extension only applies to the Revoke All consent rule. The extension does not impact other aspects of the consent revocation rules, already in effect including:
- Maintaining reasonable consent revocation methods and 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 to revoke consent,and providing alternative ways to revoke consent
- Honoring all opt-out requests no later than ten (10) business days after the request,unless your organization is a "package delivery company,"which must honor opt-out requests no later than six (6) business days from the opt-out request.
What is the FCC Seeking Comment on in its Caller Identification and TCPA Modernization FNPRM?
The FNPRM broadly addresses proposed changes to the FCC's caller identification requirements as well as modifications to the FCC's rules implementing the Telephone Consumer Protection Act ("TCPA" or "Robocall rules"). As related to the Revoke All consent rule, the FCC seeks comment on whether the current rule places undue burdens on companies and consumers by unduly restricting a consumer's ability to receive wanted calls or text messages. For example, a consumer who replies STOP to a marketing text message may still want to receive text messages related to appointments, bill payments, fraud alerts, and other informational messages. The FCC proposes to amend the Revoke All rule by allowing companies to designate specific methods for revoking consent rather than requiring them to honor "all reasonable means." To that end, the FCC asks whether any revocation methods should be required (e.g., STOP) or prohibited, what standards are needed to ensure that companies clearly and conspicuously disclose opt-out requirements, and what safeguards are necessary to prevent unduly complex revocation processes if companies are permitted to designate specific methods for revoking consent. Initial comments to the FNPRM were due on January 5, 2026, and reply comments are due on February 3, 2026.
Next Steps for Businesses
- Continue Compliance Efforts but Refrain from Making Operational and Systems Changes to Comply with the Revoke All Rule. While the FCC reviews its rules, businesses should continue to comply with all the requirements of the FCC's robocall rules, including maintaining current opt-out systems, providing reasonable opt-out methods, and ensuring they honor opt-outs within ten (10) business days. Businesses, however, may elect to wait to see what changes the FCC makes to its Revoke All rules before making operational and system changes.
- Actively Monitor the FCC's Rulemaking. Businesses should continue to monitor the FCC rulemaking proceeding (CG Docket No. 02-278) for potential modifications to the Revoke All consent rule and other changes related to Caller Identification requirements.
- File Reply Comments. Businesses still have time to file reply comments in this proceeding, whether to comment on the proposed modifications to the Revoke All rule, to provide input on other aspects of the rule, or to provide perspective on the proposed caller identification requirement changes.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
