FCC scales back TCPA ‘revoke all’ rule for informational messages, seeks comment on further consent revocation changes

On October 26, 2026, the Federal Communications Commission (FCC) published a final rule (91 F.R. 67214) (the Order) revising its Telephone Consumer Protection Act (TCPA) consent revocation rules, applicable to robocalls and automated text messages, which the FCC first announced last month. Most significantly, the Order abandons the “revoke all” approach for informational messages, allowing callers to treat an opt-out of an informational call or text as applying only to the particular category of informational message that triggered the opt-out, while an opt-out of any promotional message still revokes consent to all advertising and telemarketing messages. The Order also allows callers to designate an exclusive method for revoking consent and widens the fraud alert exemption for financial institutions. In this Legal Development, we detail these changes and explain a related proposed rule for which the FCC is seeking comment.

Background

In a 2024 order, the FCC adopted section 64.1200(a)(10) of its TCPA rules, which included a “revoke all” requirement under which an opt-out from one type of call had to be treated as an opt-out from all calls from that caller that require consent. The 2024 order took effect April 11, 2025, but the FCC postponed the effective date of the “revoke all” provision to January 31, 2027, and sought comment on ways it could “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.”

Scope of revocation for informational versus promotional messages

With the current Order, the FCC has announced a new approach to the required scope when a consumer revokes consent to be called or texted. The central change is that informational messages and promotional (advertising or telemarketing) messages are now treated differently, as follows:

• Informational calls and texts: A caller may treat a revocation made in response to an informational message as applying only to “the specific category of informational calls and text messages to which the revocation was directed,” rather than to all informational messages. An informational call is one that contains no advertisement and is not telemarketing. For example, if a consumer opts out in response to a payment reminder, the caller must implement the opt-out as to payment reminders but needs not do so for other types of informational messages, such as fraud alerts, multifactor authentication messages, appointment reminders, or utility outage notices.
• Promotional calls and texts: On the other hand, an opt-out made in response to a call or text that contains an advertisement or constitutes telemarketing revokes consent to all future advertising and telemarketing calls and texts from that caller. As a result, one opt-out is enough to stop all of a caller’s marketing robocalls. The FCC also reminded telemarketers that an opt-out request applies to the particular entity making the call and all affiliated entities that the consumer would reasonably expect the opt-out to cover.

Designating an exclusive method of revocation

The Order also allows callers to designate any of these three methods as the exclusive method by which consumers can revoke consent: (1) an automated voice or key-press opt-out on a call; (2) a reply text using one of the standardized words (“stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe”); or (3) a website or telephone number. A caller that designates a method must clearly and conspicuously disclose it on each call or in each text. Text senders can meet this requirement by naming just one standardized word, but they must still honor any of the seven. Callers that do not designate an exclusive method must keep honoring revocations made by any reasonable means.

Importantly, the change does not alter opt-out mechanisms the rules already require for particular calls. For example, exempted calls and prerecorded-voice calls that introduce an advertisement or constitute telemarketing must still provide the automated voice or key-press opt-out specified in section 64.1200(b)(3), and exempted calls to wireless numbers must still offer the opt-out methods specified in section 64.1200(a)(9).

'Reliable source' standard for fraud alerts

Financial institutions relying on the fraud-alert exemption may now contact wireless numbers obtained from a “reliable source,” not just numbers the customer provided. A “reliable source” includes numbers supplied by a spouse or other family member who is authorized to be on the account, obtained when the customer calls the institution, or included in records obtained from another financial institution. The exemption’s other conditions remain, including the limit of three messages per event over a three-day period and the requirement to honor opt-outs immediately, and the FCC encouraged use of the Reassigned Numbers Database. The FCC granted the American Bankers Association’s 2015 petition for reconsideration to this extent but declined to extend the exemption to other types of messages or to businesses other than financial institutions.

Effective date

The rule changes take effect on November 25, 2026. The revised section 64.1200(a)(10) will supersede the delayed January 31, 2027, effective date of the “revoke all” provision, so the original “revoke all” requirement will never take effect as written. The FCC declined a request to delay the effective date by up to 12 months. Separately, the FCC delegated authority to its Consumer and Governmental Affairs Bureau to reorganize section 64.1200 in plain language, without substantive changes, and expects to seek comment on proposed revisions.

Related action: Comment requested on proposed rule

In a related action, published at 91 F.R. 67239, the FCC seeks comment on several additional proposed changes to its consent revocation rules, including the following:

• Shorter deadline to honor revocations: Whether to cut the current maximum of 10 business days for a caller to honor a revocation request to seven business days, and whether the deadline should differ for callers that designate an exclusive revocation method.
• Two-way texting: Whether to remove the provision that allows callers to require consumers to revoke consent by use of one-way texting protocols when accompanied by a disclosure and an alternative opt-out method, and whether callers should be required to provide consumers the ability to opt out by reply text.
• “Revoke all” method: Whether callers that limit revocations to a single message category should be required to offer a way to revoke consent to all messages that require consent, and whether that method must be automated. The FCC also seeks comment regarding a request for clarification that revocation requests apply only to the telephone number for which consent has been revoked rather than extend to all telephone numbers associated with a customer’s account.
• Affiliates, lines of business, and divisions: Whether to modify or expand the current do-not-call affiliate standard to cover all robocalls or to adopt a proposed new section 64.1200(a)(13), which would treat an affiliate, line of business, or division as a separate caller if it obtains its own consent and identifies itself as that affiliate, line of business, or division in all calls and texts.
• Other revocation changes: Any other updates, particularly in response to changes in technology and industry practices, including shortening the list of standardized revocation words, removing the rebuttable presumption in section 64.1200(a)(11), expanding the existing confirmation-text rule to allow a confirmation call or text in response to a revocation, and allowing texts that ask the consumer to clarify which message category the revocation was meant to cover.

Comments are due by November 25, 2026, and reply comments are due by December 28, 2026.

Takeaways and practical considerations

• To benefit from category-specific opt-outs, businesses should map their informational programs into distinct categories, such as fraud alerts, payment reminders, and appointment reminders. The Order does not define a “category,” so these lines should track what a consumer would reasonably understand an opt-out to cover. Promotional content should stay out of informational messages: A message containing any advertisement is not informational, so the category-specific approach is unavailable for messages that contain promotional information, and an opt-out ends all of that caller’s marketing communications.
• Another important step for many businesses will be choosing one or more of the three approved methods as their exclusive opt-out channel. Without that designation, a caller must keep honoring revocations made by any reasonable means. Once a method is designated, it must be clearly and conspicuously disclosed on every call and in every text, and any opt-out mechanism the rules separately require for particular calls must remain in place.
• Financial institutions should also update fraud alert procedures to reflect the new reliable-source standard. Systems should be built with the proposed rule in mind, since a shorter deadline to honor revocation requests, mandatory two-way texting, or a required “revoke all” option could follow. The Order offers real relief, but only to companies that designate an opt-out method, disclose it consistently, and organize their messaging programs to use the new flexibility.
• Businesses should also consider submitting comments on the proposed rule by November 25, 2026, if any of the open issues—such as a shorter deadline to honor revocation requests or mandatory two-way texting—are meaningful to their operations.