FCC Delays Effective Date of TCPA Revocation of Consent Rules

Just days before the “reasonable methods” provision of the Federal Communications Commission’s (FCC) new consent regulations under the Telephone Consumer Protection Act (TCPA) was set to take effect on April 11, 2025, the commission has announced a one-year delay.

Originally adopted in the FCC’s order issued on February 16, 2024, the provision requires businesses to honor consumer revocations of consent through any “reasonable method.” Under this rule, a revocation would be considered definitive, barring further calls or texts to the consumer. For example, if a consumer replies to a text message with words such as “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe,” that response must be treated as a valid revocation of consent to receive future text messages. 

The rule goes further by stating that even messages lacking these explicit keywords may qualify as valid revocation requests —“if a reasonable person would understand those words to have conveyed a request to revoke consent.”

If consumers are unable to respond to messages due to technical limitations, companies must disclose those limitations and offer alternative opt-out instructions or methods, such as a dedicated website or phone number. Businesses are required to honor revocation and internal do-not-call requests as soon as possible, but no later than 10 days after receipt.

The delay comes in response to a waiver request from several banking and financial institutions. In its review, the FCC determined that additional time is needed for businesses to implement the necessary revocation procedures, particularly for organizations that rely on multiple communication systems or operate across various departments and vendors. The extension is intended to allow for cost-effective, compliant implementation of the new rules.

The delay applies only to the effective date of 47 C.F.R. §§ 64.1200(a)(10). All other amendments and rules published in the Federal Register in compliance with the FCC’s February 16 order remain scheduled to take effect on April 11, 2025.