Privacy & Cybersecurity Law Blog

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

On October 11, 2024, the FCC published amendments and additions to the TCPA regulation, including new 47 CFR § 64.1200(a)(10), which is designed to strengthen consumers’ ability to revoke consent to receive calls or text messages. 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,” drew 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 global revocation rule until April 11, 2026.

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.” The request for comment targeted the impact of the global revocation rule on calls/texts from health care providers and financial institutions, as well as fraud alert-related calls/texts. In its order extending the waiver to January 2027, the CBG cited the October 2025 rulemaking proceeding and “the possibility the Commission may modify the existing requirement.” The scope of any such modifications, however, is unknown and likely will be narrowly tailored (similar to certain existing exceptions in the TCPA regulations).

For more information on the rule, read our full client alert.