FCC Delays TCPA’s ‘Revoke All’ Rule to January 31, 2027: What CallShaper Clients Need to Know
The FCC has once again extended the effective date for the TCPA “Revoke All” rule. The new date is January 31, 2027.
If enacted, this rule would change how opt-outs work. An opt-out for one type of call would count as a comprehensive opt-out for all types. This delay gives the FCC more time to consider modifications. It also aims to help businesses avoid unnecessary compliance costs during the rule-making process.
What CallShaper Clients Must Do Now
The full “Revoke All” rule is currently on hold. However, you must remember that all other TCPA rules remain fully enforceable. You must comply with these existing consent revocation rules immediately.
It is critical to ensure your processes meet the following requirements:
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Honoring Reasonable Methods: You must honor consumer consent revocations. This applies to any “reasonable method” a consumer chooses.
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Standard Keywords: Text replies using standard keywords are automatically reasonable. These include words like “stop,” “quit,” “cancel,” or “unsubscribe.”
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Non-Standard Keywords: You must also treat non-standard keywords as valid. This applies if a reasonable person would understand the words as an opt-out request.
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Dedicated Channels: You can set up specific websites or phone numbers to process opt-outs. The FCC considers these a reasonable method.
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Technical Limitations: Some consumers cannot reply to texts due to technical limits. In this case, you must disclose this limitation. You must also provide other clear opt-out instructions on every text message.
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Time to Comply: Businesses must honor revocations and internal DNC requests quickly. You must process these as soon as possible, and no event later than 10 business days.
Moving Forward
We encourage all clients to discuss this topic with their legal counsel. You should maintain full compliance with all existing revocation requirements. Please continue monitoring the FCC for further developments.