FCC Delays TCPA Consent Revocation Rule to January 31, 2027

The Federal Communications Commission (FCC) has issued a new order delaying enforcement of a key provision of the TCPA consent revocation rules. In Order DA-26-12A, released by the FCC’s Consumer and Governmental Affairs Bureau (CGB), the agency extended the effective date of the cross-channel consent revocation requirement until January 31, 2027.

The delayed provision applies to 47 C.F.R. § 64.1200(a)(10) and would require businesses to treat a consumer’s revocation of consent for one type of robocall or robotext as applying to all future robocalls and robotexts from that caller, even when communications relate to unrelated matters.

The FCC cited “good cause” for the extension, noting the complexity of implementation, the need for additional review of industry feedback, and the potential compliance burden on affected businesses.

What the TCPA requires today

Under the Telephone Consumer Protection Act (TCPA), callers and texters must obtain a consumer’s prior express consent before delivering autodialed or prerecorded calls or text messages.

In February 2024, the FCC adopted a TCPA Consent Order that updated how consumers may revoke that consent. The order clarified that consumers may revoke consent using any reasonable method and that businesses must honor valid revocation requests within a defined timeframe. These changes expanded consumers’ opt-out rights and increased compliance obligations for consent management and revocation tracking.

The cross-channel (“revoke-all”) consent provision

The FCC’s 2024 TCPA Consent Order also introduced a cross-channel consent revocation requirement, often referred to as the “revoke-all” rule. Under this provision, a consumer’s revocation of consent for one robocall or robotext would be required to apply broadly across all future robocalls and robotexts from the same caller, even when those communications relate to unrelated matters.

This requirement raised significant operational and technical concerns, particularly for organizations managing multiple campaigns, business lines, or communication purposes across voice and text channels.

As previously reported by Convoso, the FCC granted an earlier delay of this provision to allow businesses more time to assess system limitations and prepare for compliance. Read Convoso’s prior coverage on the FCC’s prior delay→

What has not changed

The FCC’s latest order applies only to the cross-channel consent revocation requirement. Other TCPA consent rules adopted in 2024 remain in effect, including consumers’ ability to revoke consent through reasonable means and businesses’ obligation to process revocation requests promptly.

RELATED CONTENT: TCPA Compliance Checklist: Best Practices for Call Centers

What businesses should do now?

While the FCC’s latest action provides additional time to prepare for cross-channel consent revocation compliance, businesses should continue to invest in TCPA compliance strategies, including consent tracking, revocation management, and system readiness.

For teams evaluating how to operationalize these requirements, Convoso’s compliance tools are designed to support TCPA-aligned calling and messaging practices.

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