On January 6, 2026, the Federal Communications Commission (“FCC”) entered an order again delaying the effective date of the “revoke-all” rule from April 11, 2026 to January 31, 2027. By way of background, on February 16, 2024, the FCC released an Order relating to the ability of consumers to revoke consent to receive unwanted communications. In so doing, it adopted 47 C.F.R. § 64.1200(a)(10) requiring, in relevant part, that once consent is revoked, a caller may no longer make robocalls or send robotexts to a called party absent an exemption to the consent obligation.
The Rule was supposed to take effect on April 11, 2025, however, on April 7, 2025, the FCC granted a waiver delaying its effective date until April 11, 2026. Notably, on October 29, 2025, the FCC sought comment on, among other things, ways it can modify the requirement that a caller treat an opt-out request made in response to one type of call to be an opt-out request for all types of calls or to modify it to give consumers greater control over their right to stop unwanted calls.
In the January 6 Order granting the additional extension, the FCC noted that it:
recently initiated a rulemaking proceeding to “seek comment on ways we can modify the requirement that a caller must treat an opt-out request made in response to one type of call to be an opt-out request for all types of calls or to modify it to give consumers greater control over their right to stop unwanted calls.” Given the possibility the Commission may modify the existing requirement, we find that good cause exists and the public interest is served by extending the waiver. This extension will allow the Commission to fully assess the record compiled in response to this request for comment on this matter. Multiple organizations have indicated that, absent a delay, they will face significant hardship and resource burdens to comply with the rule. For example, several electric utilities report that they would need to invest “substantial funds, personnel resources, and time” to modify “communications systems and coordinate with third-party vendors.” A further extension of the rule’s effective date until the Commission decides whether to change the rule will avoid premature and potentially unnecessary compliance efforts and costs.
A copy of the Order can be viewed by clicking here.
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