The Consumer and Governmental Affairs Bureau (“CBG”) has extended, to January 31, 2027, the effective date of the Federal Communications Commission’s (“FCC”) Telephone Consumer Protection Act (“TCPA”) “global revocation” rule.[i]  

As background, on October 11, 2024, the FCC published amendments and additions to the TCPA regulation including new 47 CFR § 64.1200(a)(10) – designed to strengthen consumers’ ability to revoke consent. Most of those amendments took effect on April 11, 2025. But the “global revocation” amendment that required callers to “treat a request to revoke consent made by a called party in response to one type of message as applicable to all future robocalls and robotexts from that caller on unrelated matters,” sparked comments from numerous stakeholders. In response to waiver requests from various organizations including financial institutions and utilities, the FCC granted an initial waiver delaying the effective date of this limited portion of the rules until April 11, 2026.

Then, on October 29, 2025, the FCC requested comments regarding whether the global revocation rule harms consumers and whether there is potential to modify the rule to “give consumers greater control over their right to stop unwanted calls” without “unduly restrict[ing] consumers’ ability to receive wanted calls.”[ii] The request for comment targets the impact of the global revocation rule on healthcare providers, financial institutions, and fraud alert related calls/texts. In its order extending the waiver to January 2027, the CBG cites as good cause the October 2025 rulemaking proceeding and “the possibility the Commission may modify the existing requirement.” However, the scope of any such modifications is unknown and will likely be narrowly tailored (similar to certain existing exceptions in the regulation).

What does the rule require?

The waiver extension is limited to the 47 CFR § 64.1200(a)(10) amendment that “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.”[iii] This change requires callers to honor an opt out as an opt out of both calls and text message and an opt out from all topics of communication (i.e., marketing and nonmarketing), unless otherwise specified by the called party.

The FCC sought to make the revocation process simple and easy. But the delayed portion of the global revocation rule had a far-reaching impact and imposed operational challenges. It required callers to apply a revocation request made in response to one type of message to all future calls and texts. Stakeholder comments raised concerns about the impact of the rule on their ability to communicate fraud alerts and other important information to customers which would negatively impact consumers. Comments also reflected the need to “invest ‘substantial funds, personnel resources, and time’ to modify ‘communications systems and coordinate with third-party vendors.’”[iv]

Hunton will continue to monitor for additional developments that may follow the FCC’s request for comment on the efficacy of portions of the TCPA rules. Given the onerous operational challenges required to implement the ‘global revocation’ rule, callers should continue targeting compliance by January 2027. Callers should also review any contracts with SMS and call vendors to confirm whether similar ‘global revocation’ processes separately required by those vendors also have been delayed.

What portions of the 2023 Rule are Already in Effect?

As a reminder, the FCC’s waiver does not affect the remaining rule changes, which became effective on April 11, 2025. Callers should already be:

• processing requests for which the party is seeking an opt-out within a reasonable time not to exceed 10 business days, as opposed to the prior outer limit of 30 days;
• recognizing and processing the expanded list of opt-out commands (“STOP,” “QUIT,” “END,” “REVOKE,” “OPT OUT,” “CANCEL,” or “UNSUBSCRIBE”.) and any other opt-out request made using any reasonable method to clearly express a desire not to receive further calls or texts;
• allowing users to opt out of exempted texts or calls if they request an opt-out in response to one of those messages; and
• providing a clear, conspicuous disclosure and an alternate, reasonable method of opting out if two-way texting is not supported, so that the party knows how to opt out in response to a text.

[i] See the Order here: DA-26-12A1.pdf

[ii] See Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor, Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Ninth Further Notice of Proposed Rulemaking in CG Docket No. 17-59, Seventh Further Notice of Proposed Rulemaking in WC Docket No. 17-97, Further Notice of Proposed Rulemaking in CG Docket No. 02-278, FCC 25-76 at paras. 101-04 (2025) (2025 TCPA FNPRM).

[iii] See Order, In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, No. DA 25-312 (Apr. 7, 2025).

[iv] Id. at ¶ 8, n.21.