On April 7, the Federal Communications Commission (FCC) issued an Order (Extension Order) granting a limited waiver that delays the effective date of certain portions of Section 64.1200(a)(10) of the FCC's rules by one year – specifically, the section requiring callers to treat a request to revoke consent as applicable to all future communications from the caller on unrelated matters. The new effective date for this specific rule is now April 11, 2026.
Background
The Telephone Consumer Protection Act (TCPA) generally requires prior express consent for robocalls and robotexts, with certain exemptions. On February 16, 2024, the FCC released a TCPA Consent Order, which included a section stipulating that if a called party revokes consent by a reasonable method, the caller must cease all future robocalls and robotexts to that party. The TCPA Consent Order noted that certain words (including "stop," "quit," "revoke," "opt out," "cancel," "unsubscribe," and "end"), when sent in response to a text, constitute a reasonable revocation of consent under the TCPA. If one of these methods is used, a party must cease all robocalls and robotexts with the consumer within 10 business days from the receipt of the revocation request. The original compliance date for this rule was set for April 11, 2025 – this coming Friday.
Waiver Request
In March 2025, several associations representing banks and financial institutions requested a one-year waiver, citing significant challenges in modifying existing communication systems to comply with portions of the new rule. These modifications are especially burdensome for larger organizations with multiple business units, such as healthcare and financial companies, and smaller businesses who often rely on manual processes.
The FCC found good cause to grant the waiver, emphasizing that compliance with the original deadline would be inconsistent with public interest, as it would impose undue hardship on affected parties. The FCC acknowledged that businesses need additional time to ensure they can implement necessary changes and process revocation requests in a cost-effective manner without significant disruption. The waiver aims to ensure that affected parties have the necessary time to comply with the rule in a way that minimizes business impact.
Conclusion
Businesses now have an additional year to comply with the TCPA consent revocation rule– but only with respect to the requirement that callers treat a revocation request made in response to one type of message as applicable to all future communications on unrelated matters. The waiver does not extend the effective dates for the other provisions adopted in the TCPA Consent Order. Importantly, the Extension Order does not change businesses' existing obligation to honor reasonable opt-out requests, including honoring the keywords for revocation mentioned above.
The new compliance date for the applicable portions of Section 64.1200(a)(10) in the Extension Order is now one year later, April 11, 2026. The remainder of the TCPA Consent Order requirements will still take effect this Friday, April 11, including the obligation to process opt-out requests within 10 business days and to clearly disclose when consumers cannot opt out via text message, among others.
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