On April 7, 2025, the Federal Communications Commission issued an order delaying the effective date of a key provision in its Telephone Consumer Protection Act rules. The rule, originally set to take effect on April 11, 2025, required businesses to honor consent revocation requests uniformly across different business units and, in some situations, different call or text types (marketing vs. non-marketing). The effective date has been postponed until April 11, 2026.
The New Consent Revocation Requirement
In February 2024, the FCC adopted the TCPA Consent Order, introducing amended rules for robocalls and robotexts. Among these changes was Section 64.1200(a)(10), which mandates that any reasonable method used by a consumer to revoke consent—such as replying "stop," "end," or "unsubscribe"—must halt all future communications from the caller, subject to limited exceptions. This provision sought to simplify the opt-out process for consumers while requiring that businesses apply revocation requests universally.
The rule is complex and posed logistical challenges for large organizations with decentralized communication systems and smaller ones relying on manual processes. For example, a consent revocation request sent in response to a marketing text requires stopping all marketing texts across business units, but the business may ask for clarification of the consumer's intent within five minutes. An opt-out sent in response to an informational or transaction message should be recognized as a revocation to consent for both non-marketing and marketing messages. Organizations operating across multiple business units or vendors likely needed significant system overhauls to bring programs into compliance.
One-Year Extension: Rationale and Implementation Timeline
In response to the banking industry's request for more time to comply, the FCC granted a one-year waiver for Section 64.1200(a)(10). The Commission cited good cause to delay the rule, noting that strict compliance would impose undue hardship on affected parties and that granting the waiver was in the public interest. Without additional time, businesses faced substantial costs and operational inefficiencies.
The waiver only applies to this specific provision; other TCPA Consent Order rules—regarding a shortened timeframe for honoring consent revocation and confirmation messages—remain unchanged.
The one-year delay gives businesses time to update their systems and prioritize TCPA compliance. As April 2026 approaches, stakeholders should expect ongoing scrutiny of implementation efforts.
We find that the public interest is served by a waiver. As noted, the record confirms that a limited delay is necessary to provide sufficient time for affected parties to process revocation requests received across different business units.
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