On April 7, the FCC issued an order staying the effective date of a key provision in its Telephone Consumer Protection Act (TCPA) rules. The provision — originally set to take effect on April 11, 2025—would have required that a consumer's revocation of consent apply broadly to all robocalls and robotexts from a sender, not just the type of message that prompted the opt-out.
The stay follows petitions from banking industry groups, who raised concerns that the rule would force institutions to block important customer communications, such as fraud alerts or low balance warnings, based solely on a consumer opting out of unrelated messages.In response, the FCC agreed that affected senders need additional time to prepare.
The now-delayed rule would have required:
- Broad application of revocation. A single opt-out message—such as replying "stop" to a promotional text— would revoke consent for all future robocalls and texts from that sender, including those unrelated to the original message.
- Universal treatment of revocation. Senders would be required to apply the opt-out across all communication lines or departments, rather than limiting it to the context in which the revocation occurred.
Companies now have until April 11, 2026 to comply with the global revocation requirement. Other provisions from the 2024 TCPA Consent Order—such as honoring standard opt-out keywords and processing revocations within ten business days—will still take effect as planned on April 11, 2025.
Putting It Into Practice: The FCC's decision provides short-term relief for financial institutions and other regulated entities preparing for the rule. This development reflects ongoing efforts by federal regulators to balance consumer protection with operational feasibility (previously discussed here, here, and here). Nonetheless, businesses should continue preparing for full compliance with the global revocation rule by April 2026 and closely monitor any strengthening of consumer protection efforts at the state level (previously discussed here, here, and here).
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