FCC Reverses Course: Internal “Do-Not-Call” Rule Will Stay

When the Federal Communications Commission (FCC) first released its draft rulemaking on October 8, 2025, it looked as though the agency was ready to scrap one of the oldest parts of the Telephone Consumer Protection Act (TCPA): the internal “do-not-call” list rule. That rule requires every business that makes marketing calls to keep an internal list of people who have asked not to be called again.

In the draft, the FCC proposed eliminating that requirement as part of its plan to remove what it called “outdated” or “duplicative” robocall rules. The reasoning was that newer technologies such as STIR/SHAKEN and call authentication might make some older rules unnecessary. The proposal immediately raised eyebrows from consumer groups, who warned that removing the internal list would strip away a core privacy protection and make it harder for businesses to prove they are following the law.

Three weeks later, the FCC changed course. In the amended version adopted on October 28 and released October 29, the agency deleted the proposal to repeal the internal “do-not-call” rule. The new language focuses only on cleaning up obsolete or overlapping provisions and confirms that core consumer-protection obligations will remain in place.

For businesses, that means nothing changes. Companies must continue to maintain internal “do-not-call” lists and honor opt-out requests. They must train employees and vendors to check those lists before dialing and keep records for at least five years. Those duties still apply even as the FCC moves ahead with new rules for caller authentication and verified caller ID.

In short, while the FCC is modernizing how calls are authenticated and displayed, it is keeping the consumer protections that have long defined compliance under the TCPA. Companies that continue to track and honor internal “do-not-call” requests will be well positioned to adapt to the new rules without additional risk.