FCC Amends TCPA Consent Revocation Rules

By Ariel Yosefi, Tal Habas & Itay Siani

On 30 September 2026, the Federal Communications Commission (“FCC”) adopted a “Report and Order and Further Notice of Proposed Rulemaking” (FCC 26-67) (the “Order”), amending its Telephone Consumer Protection Act (“TCPA”) rules governing consent revocation for autodialed and prerecorded calls (“robocalls”) and text messages.

Background

The TCPA and the FCC’s implementing rules restrict certain calls and text messages, subject to applicable consent requirements and exceptions.

In 2024, the FCC adopted rules requiring callers to honor consent revocation requests made through any reasonable method. Those rules also introduced a broader “revoke all” approach, under which revocation in response to one type of informational robocall could extend to all future robocalls requiring consent. The effective date of the relevant “revoke all” provision was subsequently delayed by waiver until 31 January 2027.

In the Order, the FCC revises this framework to give consumers greater control over the categories of informational robocalls and text messages they receive, while allowing callers to process revocation requests more efficiently. The amendments address the scope of consent revocation, the methods callers may designate for opting out, and the exemption from consent requirements for certain informational robocalls made by financial institutions.

Category specific revocation of informational communications

According to the Order, callers may treat a revocation request made in response to an informational call or text message as applying only to the specific category of informational robocalls and text messages to which the request relates, rather than to all communications from that caller. For example, a consumer who opts out of payment reminders may continue to receive fraud alerts, multi-factor authentication messages or appointment reminders, provided the applicable requirements for those communications are otherwise satisfied.

This change applies only to informational communications that contain no advertising or telemarketing. A revocation request made in response to a call or text message that contains an advertisement or constitutes telemarketing revokes consent for all future calls and text messages containing advertising or constituting telemarketing from that caller.

Designation of exclusive revocation methods

The Order permits callers to designate one or more of the following methods as the exclusive means of revoking consent:

• Automated voice or keypad opt-out: an automated, interactive voice or key-press activated opt-out mechanism during a call;
• Reply text message: a reply containing any of seven specific standard words (“stop”, “quit”, “end”, “revoke”, “opt out”, “cancel”, or “unsubscribe”);
• Designated website or telephone number: a website or telephone number provided by the caller to process opt-out requests.

The designated method must be clearly and conspicuously disclosed on the call or in the text message, as applicable. Where a reply text is designated as the exclusive method, a sender may disclose just one of the standard terms in each text message but must recognize all seven terms as valid revocation requests.

A caller that designates one or more of these methods as exclusive is not required to process revocation requests submitted through other methods. Callers that do not designate an exclusive method must continue to honor requests made by any reasonable means. For those callers, a request made through a method not listed in the rule creates a rebuttable presumption that consent has been revoked once the consumer produces evidence of the request, and whether the request was made in a reasonable manner is assessed on the totality of the circumstances.

The existing rule for text messages sent using a protocol that does not permit replies continues to apply. The sender must clearly and conspicuously disclose in each text message that two-way texting is unavailable due to technical limitations and provide reasonable alternative methods for revoking consent.

Revocation requests must continue to be honored within a reasonable time, not exceeding ten business days after receipt.

The Order also addresses confirmation text messages. A text message sent solely to confirm a consumer’s revocation request is permitted, provided it contains no marketing or promotional information. If sent within five minutes of receipt of the request, it is presumed to fall within the consumer’s prior express consent. If sent later, the sender must demonstrate that the delay was reasonable.

These amendments do not replace existing opt-out requirements applicable to certain exempt calls or calls that contain advertising or constitute telemarketing. Callers subject to those requirements must continue to provide the applicable opt-out mechanisms in addition to complying with the amended consent revocation rules.

Expansion of the financial institution exemption

The Order expands a limited exemption that permits financial institutions to make certain informational robocalls and text messages to wireless numbers without prior consent.

Previously, the exemption required the wireless number to have been provided directly by the customer to the financial institution. The Order has expanded this condition to permit use of numbers obtained from a “reliable source”, which includes numbers: (i) supplied by a spouse or other family member authorized to be on the account; (ii) obtained when the customer calls the financial institution; or (iii) included in records obtained from another financial institution.

The amendment is intended to facilitate important, time-sensitive communications, including alerts concerning potential fraud or identity theft. It does not create a general exemption from the TCPA for financial institutions. The exemption’s other conditions continue to apply.

Further proposed changes

In addition to the amendments adopted, the FCC is seeking comments on potential additional changes to its consent revocation framework, including:

• Shortening the maximum period for honoring revocation requests from ten to seven business days;
• Eliminating the exception that permits text senders to use one-way texting protocols that do not allow consumers to revoke consent by reply text;
• Requiring callers to provide a one-step method for revoking consent to all future robocalls; and
• Clarifying how revocation requests apply to affiliated entities and separate lines of business or divisions.

These proposals remain under consideration and have not yet been adopted. Comments are due by 25 November 2026, and reply comments by 28 December 2026. Separately, the FCC has delegated authority to its Consumer and Governmental Affairs Bureau, in consultation with the Enforcement Bureau, to reorganize the relevant rules and restate them in plain language, without substantive change.

Effective date

The amended rules were published in the Federal Register and take effect on 25 November 2026. 

Companies that place robocalls or send text messages to consumers in the United States should assess the impact of these amendments on their consent management practices ahead of the effective date. Please feel free to contact us if you have any questions regarding the Order and its practical implications.