The Federal Communications Commission (FCC) has once again extended the effective date of the Telephone Consumer Protection Act (TCPA) “Revoke All” rule to January 31, 2027. This rule, if enacted, would require an opt-out for one type of call to be treated as a comprehensive opt-out for all types. The delay provides the FCC with more time to consider modifications and aims to avoid unnecessary compliance costs for businesses during the ongoing rule making process.

What CallShaper Clients Must Do Now

While the full “Revoke All” rule is on hold, it is crucial to remember that all other existing TCPA consent revocation rules remain fully enforceable and must be complied with immediately.

It is critical to ensure your processes meet the following existing requirements:

  • Honoring Reasonable Methods: You must honor consumer consent revocations made through any “reasonable method.”
  • Standard & Non-Standard Keywords: A consumer’s text reply using standard keywords (e.g., “stop,” “quit,” “cancel,” “unsubscribe”) is automatically reasonable. You must also treat non-standard keywords as a valid revocation if a reasonable person would understand the words to convey an opt-out request.
  • Dedicated Channels: A request submitted to a website or phone number specifically set up to process opt-outs is considered a reasonable method.
  • Technical Limitations Disclosure: If consumers cannot reply to texts due to technical limitations, you must disclose this limitation and provide other clear opt-out instructions on each text message.
  • Time to Comply: Businesses must honor revocations and internal DNC requests as soon as possible, and no event later than 10 business days.

We encourage all clients to discuss this topic with their legal counsel and maintain full compliance with all existing revocation requirements, and to continue monitoring FCC developments.