It’s official. FCC commissioners adopted new TCPA consent-revocation rules at the September 30, 2026 open meeting, carrying forward the draft order largely as written. Take note: a countdown to the new effective date just started.
The Compliance Clock Is Now Running
The revised rules take effect 30 days after they’re published in the Federal Register, and that compliance date will replace the January 31, 2027 date the Commission had set for compliance with the remaining components of the original “revoke-all” rule. The Commission hasn’t set that publication date yet, and will issue a separate Public Notice once it does. That notice, likely to be issued in the next few weeks, will put an exact effective date on the calendar.
What the Rule Actually Does
In practice, the order does three things:
- Informational revocations get narrower. It lets callers treat a revocation of prior express consent tied to one category of informational communications, such as a payment reminder, as applying only to that category rather than to every informational message from that caller. This will allow callers to give consumers flexibility in their revocation of consent options. Revocations of prior express written consent for marketing and advertising communications must still be effective for all marketing and advertising communications.
- Callers can designate one way to revoke consent. It lets callers designate a single exclusive way to revoke prior express consent or prior express written consent for use of an automatic telephone dialing system or artificial or prerecorded voices from a list of Commission-provided options: an automated key-press option, a standardized text keyword reply, or a dedicated website or phone number, as long as that method is clearly disclosed to the consumer. Callers who do not disclose an election to the consumer still have to honor revocation requests made any reasonable way.
- Financial institutions get more room on fraud alerts. It gives financial institutions more flexibility to source phone numbers for fraud and security alerts from reliable sources beyond what the customer provided directly, including numbers from an authorized family member on the account.
The order also hands the Consumer and Governmental Affairs Bureau the job of reorganizing the TCPA’s rules in plain language. The Commission was clear that their delegation of authority does not allow the Bureau to make revisions that change the actual obligations imposed by the rules.
Note that a companion Further Notice keeps several bigger questions open for comment: a shorter window for honoring revocation requests, a two-way texting requirement so consumers can reply to opt out, a mandatory single method to revoke everything at once, and how all of this applies across affiliates and separate business lines. Comments will be due 30 days after Federal Register publication, replies 60 days after.
On Your To-Do List Now
- Calendar the Federal Register publication date and the Commission’s Public Notice once they’re out; that’s what starts the 30-day clock.
- Decide whether to designate a single revocation channel for your call and text programs, and build in the required disclosure if you do.
- Confirm your systems can distinguish informational categories from marketing so revocations route correctly.
- If you’re a financial institution, revisit your fraud alert number-sourcing policies in light of the expanded exemption.
- Weigh in on the Further Notice if any of its questions affect how your organization operates.
If you’d like help evaluating how the new revocation rules fit your current consent and compliance workflows, or need support preparing comments on the Further Notice, please reach out.
