On September 9, 2026, the Federal Communications Commission (FCC) issued a final rule amending the previously issued (and subsequently delayed) “Revoke All” rule applicable to the Telephone Consumer Protection Act (TCPA).[1] Through its amendments, the FCC recognized the significant operational burdens imposed by the “Revoke All” rule and that the “all-or-nothing revocation” approach is often inconsistent with the consumer’s intent. Significantly, callers may now designate an FCC-approved opt-out method as their exclusive method of opting out. The rule also acknowledges that the TCPA regulations have become unwieldy and contemplates a future non-substantive rulemaking to streamline and re-organize 47 C.F.R. § 64.1200.

These rules will become effective 30 days after publication in the Federal Register and the rulemaking explicitly supersedes the earlier extension. Therefore, these amended rules will likely become effective before January 2027.

Hunton stands ready to assist callers in reviewing their TCPA procedures to confirm compliance with these new rules that significantly affect current TCPA processes, identify opportunities to streamline processes based on clarifications presented in the final rule, and assess and comment on the notice of proposed rulemaking.

• No Default “Revoke-All” for Non-Marketing Calls and Texts: The rule now establishes two revocation standards: one for informational/non-marketing texts and calls and a second for marketing calls and texts.
  • For “informational” and other non-marketing calls or texts (meaning those that do not include any advertising or marketing content), an opt-out request made in response to that call or text acts only as revocation of consent for that specific category of messages (and not for all other call/text topics). For example, if a consumer revokes consent in response to payment reminders, the caller must stop sending payment reminders but could continue sending calls and texts on other non-marketing topics—to which the customer has consented—such as appointment reminders or outage information.
  • For marketing or advertising calls or texts, an opt-out request made in response to that call or text acts as a revocation of consent for all marketing/advertising calls or texts from that caller.
• Exclusive Method of Opting Out: Callers can now designate one of the following as an exclusive method of opting out by clearly and conspicuously disclosing the designated method to revoke consent during the call or in the text. The exclusive method of opting out must be one or more of the following:
  1. an automated, interactive voice response (IVR) or key press opt-out mechanism on a call;
  2. replying to an incoming text message with any of the following standardized words: “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe”; or
  3. pursuant to a website or telephone number designated by the caller to process opt-outs.

The rule expressly provides that a caller that designates any of the methods identified above as the exclusive means of revoking consent is not required to process revocation requests made by any other means. 

This approach will help combat the influx of TCPA opt-out litigation that has flourished under the “ambiguity of the current ‘reasonable means’ standard.” If a caller chooses not to designate an exclusive method of opting out, the caller will be required to honor any “reasonable” method of opting out (i.e., the current approach).   

• Fraud Alerts from Financial Institutions: Under a narrow exemption, financial institutions will be permitted to place fraud alert calls to phone numbers “obtained from a reliable source” in addition to phone numbers provided directly by the customer to the financial institution. 

• Plain Language Updates: The FCC acknowledged that “the rules have grown increasingly lengthy and dense.” Thus, the FCC delegated authority to the Consumer and Governmental Affairs Bureau to review Section 64.1200 to ensure that the rules are organized, clear, and easy to understand (with no changes to the substance). Any proposed changes to the current rules will be subject to public comment.

Upcoming Rulemakings

The FCC also issued a Further Notice of Proposed Rulemaking for several significant topics. Interested entities should consider submitting comments on these critical categories:

• the timeframe for callers to honor revocation requests (currently 10 business days);
• whether two-way texting functionality to allow for revocation via reply text should be mandatory;
• whether to require callers to provide a method to revoke consent to all robocalls; and
• the treatment of affiliates for opt-out purposes.

[1] See the Order here: DOC-424844A1.pdf.