Well we didn’t come down to the wire like January, but it was still a little too close for comfort.

Just moments ago the FCC issued a ruling staying the most problematic parts of the TCPA revocation rule for one year. Specifically the scope of revocation ruling that would have required a caller to stop calling across all channels and for all purposes in response to a single “stop” request from a consumer.

On hold for now!

Here is the critical language from the ruling:

We find that good cause exists to justify a limited waiver of the effective date of section 64.1200(a)(10) of the Commission’s rules to the extent that it requires callers to apply a request to revoke consent made in response to one type of message to all future robocalls and robotexts from that caller on unrelated matters. For the reasons discussed herein, we delay the effective date of any such requirement until April 11, 2026. 

That’s really important folks.

The new rule section would have read as follows:

(10) A called party may revoke prior express consent, including prior express written consent, to receive calls or text messages made pursuant to paragraphs (a)(1) through (3) and (c)(2) of this section by using any reasonable method to clearly express a desire not to receive further calls or text messages from the caller or sender. Any revocation request made using an automated, interactive voice or key press-activated opt-out mechanism on a call; using the words “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe” sent in reply to an incoming text message; or pursuant to a website or telephone number designated by the caller to process opt-out requests constitutes a reasonable means per se to revoke consent. If a called party uses any such method to revoke consent, that consent is considered definitively revoked and the caller may not send additional robocalls and robotexts. If a reply to an incoming text message uses words other than “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe,” the caller must treat that reply text as a valid revocation request if a reasonable person would understand those words to have conveyed a request to revoke consent. Should the text initiator choose to use a texting protocol that does not allow reply texts, it must provide a clear and conspicuous disclosure on each text to the consumer that two-way texting is not available due to technical limitations of the texting protocol, and clearly and conspicuously provide on each text reasonable alternative ways to revoke consent. All requests to revoke prior express consent or prior express written consent made in any reasonable manner must be honored within a reasonable time not to exceed ten business days from receipt of such request. Callers or senders of text messages covered by paragraphs (a)(1) through (3) and (c)(2) of this section may not designate an exclusive means to request revocation of consent.

It is unclear, however, what–if any–portion of this rule is now in effect. The language of the FCC’s ruling staying effectiveness is laser focused on the “scope” provisions of the FCC’s previous revocation ruling– but those scope provisions are not actually written into the new rule. And the language of the new rule itself does not address the concerns animating the requests for stay that lead to the extension. So this is going to cause some headaches I think. Especially given this language:

We emphasize that this waiver extends only to section 64.1200(a)(10) to the extent discussed herein. This ruling does not otherwise delay the effective date of the other rules adopted in the TCPA Consent Order.[1] In addition, this Order does not alter the status quo relating to any other prior Commission rulings addressing revocation of consent

So yeah, a bit of a guessing game as to what provisions of (a)(10) are and are not in effect. But what we do know is that the worst appears to have been avoided for now.

Unfortunately there is no court action pending so we may still need to deal with this ruling a year from now– so don’t lose track of it. New effective date is now April 11, 2026!

In the meantime, however, R.E.A.C.H. will certainly be asking the FCC to “delete, delete, delete” this provision come Friday.

If you have questions on any of this feel free to reach out.

Full ruling here: FCC ruling staying revocation

Chat soon!