When the 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 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In a striking bit of self-reflection, the FCC’s latest draft order includes two blunt sections: “Eliminating Outdated Rules” and “More Recent Rules That Might Harm Consumers.” Together, they signal a long overdue housecleaning of the TCPA, parts of which date back to the 1990s.