FCC Delays “Reasonable Methods” Provision of New Revocation of Consent Regulations Until April 11, 2026

The FCC has delayed the “reasonable methods” provision of the new revocation of consent regulations until April 11, 2026, in its Order released just four days before the revocation rules were set to take effect on April 11, 2025.

Adopted in the FCC’s 2024 Order, the “reasonable methods” provision (to be codified at 47 C.F.R. § 64.1200(a)(10)) includes the following:

• businesses must honor consumer consent revocations through any “reasonable method”
• a consumer’s reply to a text with terms such as “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” and “unsubscribe” is considered a reasonable method
• if a consumer’s reply to an incoming text message uses words other than “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe,” the caller must still treat that reply as a valid revocation request if a reasonable person would understand those words to convey a request to revoke consent
• a consumer request submitted to a website or phone number specifically set up by the business to process opt-outs are also deemed reasonable
• if a consumer can’t respond to texts due to technical limitations, the business must disclose this limitation and provide other opt-out instructions on each text message
• businesses must honor revocations and internal DNC requests ASAP, not to exceed 10 business days

In response to a request for waiver from several banking and financial entities, the FCC found that businesses need more time to implement revocation procedures to ensure they can process revocation requests in a cost-effective manner that complies with the new revocation rules. Implementation is especially challenging for entities using several communication systems to reach consumers or for entities needing to harmonize revocations across multiple business units that interact with consumers. The FCC clarified that compliance with other provisions of the revocation rules is still required on and after April 11, 2025, such as amendments to sections 47 C.F.R. § 64.1200(a)(9)(i)(F) and (d)(3).

While the FCC’s delay will help businesses implement the tools needed to comply with the new revocation rules, it is unlikely that the rules will be thrown out entirely. First, there is no ongoing legal challenge to the rules. Second, the FCC unanimously approved the rules, which aligns with the FCC’s efforts to give consumers power to determine who they want to hear from.

Businesses should continue to prepare and implement solutions to respond and react to revocations from consumers, including: (1) modifying processes to harmonize cross-channel opt-outs (opt-outs for text systems vs. opt outs for call systems), (2) training employees involved in customer communications on what a reasonable revocation request may look like, (3) ensuring parameters are in place to determine when a text or call should be treated as a revocation, and (4) developing a review process to monitor calls and texts to ensure opt-outs are recorded.