Current standards for revocation of consent to remain in place
Last month, we reported that a new FCC regulation would make it easier for consumers to revoke previously given consent to receive marketing solicitations pursuant to the Telephone Consumer Protection Act (“TCPA”). The regulation was scheduled to take effect on April 11, 2025. On Monday, however, the FCC announced it will maintain the current status quo and delayed the effective date of the new regulation for one year.
The thrust of the now-delayed changes was that consumers would be able to revoke their consent in any reasonable manner; callers could not dictate a specific method of revocation.
The FCC’s order of April 7, 2025 stated, “we grant a limited waiver delaying the effective date of section 64.1200(a)(10) of the Commission’s rules to the extent the rule requires 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. Specifically, we find that good cause exists to delay the effective date for this requirement until April 11, 2026 to allow affected parties a reasonable opportunity to implement modifications to communications systems in a cost-effective manner to ensure that they can process revocation requests in accordance with this rule.”
The FCC reasoned that the public interest would be served by the one-year delay. “[A] limited delay is necessary to provide sufficient time for affected parties to process revocation requests received across different business units. A variety of financial and healthcare organizations confirm that in the absence of such a delay, they will incur significant hardship in the expenditure of resources to comply with the rule. As a result, we believe that the public interest is served by delaying the effective date to ensure that these parties can process revocation requests in a cost-effective manner that effectuates the preferences of the called party.”
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