FCC Hits Pause (Again) on Global Consent Revocation

If you’ve been following the FCC’s evolving rules on TCPA consent revocation, you may be feeling a sense of déjà vu. The FCC has again delayed the most controversial part of its consent revocation rule: the requirement that an opt-out to one type of call or text would apply to all future automated or prerecorded calls and texts from the same caller.

As we explained last year when the FCC first pushed the rule back to 2026, this “one opt-out stops everything” concept raised real operational challenges for companies with multiple business lines, vendors, or messaging platforms (see our prior post here: FCC Delays Part of the Consent Revocation Rule Until 2026). Now, the FCC has pressed pause once more.

What changed?

In an Order released on January 6, 2026, the FCC extended the waiver until January 31, 2027 for the portion of the rule that would require companies to treat a revocation sent in response to one type of message as revoking consent for all unrelated automated or prerecorded calls and texts from the same caller. The FCC explained that it is reconsidering this requirement in an ongoing rulemaking and wants to avoid forcing companies to invest in systems that may not ultimately be required.

What didn’t change?

The waiver is narrow. The FCC did not delay or change the obligation to honor opt-out requests within 10 business days. Companies must still accept revocation through reasonable means, including replies such as “STOP,” “CANCEL,” or “UNSUBSCRIBE,” and must stop messages once consent has been withdrawn for a particular type of call or text.

Why does this matter for companies?

For businesses with multiple departments or third-party vendors, the delayed requirement would have required significant system changes and coordination. The extension gives companies time to avoid those costs while the FCC considers whether the rule will change.

What should companies be doing now?

This is not a reason to relax TCPA compliance. Companies should continue to process opt-outs promptly and understand how consent is tracked across teams and vendors.

The FCC has not abandoned the idea of broader consumer opt-out rights, and the outcome of the current rulemaking will matter. We will continue to track developments and share updates.