Short answer: In FCC 26-67, adopted September 30, 2026 and released October 1, the FCC replaced the 2024 “revoke-all” rule before it ever took effect. Callers may now treat a revocation of an informational call or text as covering only that category of message, and they may designate an exclusive way for consumers to opt out. A STOP sent in reply to any marketing message still ends all marketing from that caller. The new rules take effect 30 days after publication in the Federal Register. As of October 17, 2026 we could not find that publication, so the current rules still apply.
If you read our April post on the revoke-all waiver, this supersedes it. The January 31, 2027 date set by the Bureau’s January 6, 2026 waiver order (DA 26-12) no longer matters: the order says the new rules “supersede the delayed effective date of the relevant portion of that rule that was previously extended to January 31, 2027.”
What was the revoke-all rule?
The FCC’s 2024 revocation order (FCC 24-24) did two things. Most of it took effect on April 11, 2025: consumers can revoke consent by any reasonable means, and callers must honor a revocation within a reasonable time, not to exceed 10 business days. One sentence of 47 C.F.R. § 64.1200(a)(10) was held back by waiver: a revocation in response to one type of message would apply to all robocalls and robotexts from that caller, including informational ones that do not need written consent.
Banks, utilities and healthcare providers argued that a customer replying STOP to a promotion would also lose fraud alerts, outage notices and appointment reminders. Chairman Carr’s statement on the new order makes the same point:
“As we have learned from experience, the Commission’s 2024 ‘revoke all’ rule did not align with consumer expectations and, in many cases, made it harder for them to get the calls they do want.”
What does FCC 26-67 change?
| Question | Rule under FCC 26-67 |
|---|---|
| A consumer revokes in reply to an informational call or text | Callers may treat it as covering only that category of informational message. |
| A consumer revokes in reply to a marketing call or text | It revokes consent to all future marketing calls and texts from that caller. |
| How can consumers revoke? | Any reasonable means, unless the caller designates an exclusive method (below). |
| Exclusive methods a caller may designate | (1) an automated voice or key-press opt-out on the call, (2) a reply text using a standardized word, (3) a website or phone number the caller provides. Callers may designate more than one. |
| Disclosure | The designated method must be disclosed clearly and conspicuously on the call or in the text. One standardized word per text, such as “Reply STOP to opt out,” is enough. |
| Standardized reply words | ”stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” “unsubscribe.” Texts may disclose one, but all seven must still be honored. |
| Deadline to honor | Unchanged: within a reasonable time, not to exceed 10 business days. |
| Fraud-alert exemption for financial institutions | Expanded so alerts can go to numbers obtained from a reliable source. |
| Effective date | 30 days after Federal Register publication. The FCC will announce the exact date by Public Notice. |
The marketing rule is the part lead generators and lead buyers should read twice. Paragraph 14 of the order is direct: “Revocation requests made in response to robocalls that contain an advertisement or constitute telemarketing revoke consent to all future robocalls containing an advertisement or that constitute telemarketing from that caller.” Nothing in the new order narrows opt-outs for telemarketing.
What is an exclusive opt-out method, and why does it matter?
Under the 2024 rules a consumer could revoke “using any reasonable method,” which left callers arguing in court about whether an unusual reply such as “please no more” counted. The FCC acknowledged that problem, citing a commenter who said the standard “has enabled a tactic where litigants intentionally bypass clear, simple, and automated opt-out instructions in favor of ambiguous phrases designed to evade recognition, thereby manufacturing lawsuits.”
Under the new rule, a caller that designates one of the three listed methods “will not be required to process revocation requests made by any other means.” The condition is disclosure: the designated method has to be stated clearly and conspicuously on the call or in the message. The FCC refused to let callers decide for themselves when and how to tell consumers about it.
Two limits are easy to miss:
- Only the three listed methods qualify. The FCC rejected a request to let callers designate a method set by another regulator, such as written notice under debt-collection rules.
- A caller that does not designate a method still has to honor revocations made in any reasonable manner.
What is still open?
The order comes with a Further Notice of Proposed Rulemaking. Comments are due 30 days after Federal Register publication and replies 60 days after. The FCC asks whether to:
- shorten or change the 10-business-day window for honoring revocations;
- require two-way texting so consumers can always reply to opt out, and whether to require it only on marketing texts;
- require callers to offer a one-step way to revoke consent to all robocalls;
- decide how revocations apply across affiliates and separate lines of business.
These issues were raised in a joint letter from the American Bankers Association, the National Consumer Law Center and ACA International. The FCC’s separate 2025 proposal to remove or loosen other TCPA rules (FCC 25-76), covering call abandonment and caller ID for prerecorded calls, is still pending.
What should lead generators, lead buyers and call centers do now?
- Choose your exclusive methods and disclose them. If you text, put “Reply STOP to opt out” (or another standardized word) in every message. If you call with prerecorded or AI voice, offer a key-press or voice opt-out and say so on the call.
- Keep honoring all seven standardized words even if your messages show only one.
- Separate informational and marketing traffic. The narrower revocation for informational messages only helps if your systems know which category each message belongs to. A promotion sent from the same number as a payment reminder makes that hard to prove.
- Keep the record. In a dispute you will need to show which opt-out method was disclosed, when the consumer revoked, which message they replied to, and when you stopped. Store the revocation next to the original consent rather than in a separate suppression list that loses the context.
- Watch for the effective date. Until the FCC’s Public Notice sets it, the current rules apply: any reasonable method of revocation, honored within 10 business days.
eConsent keeps each revocation attached to the consent certificate it cancels, with who, when and how, so the original consent and its revocation can be produced together. See Revocation and opt-out for how that works.
Sources
- FCC 26-67, Report and Order and Further Notice of Proposed Rulemaking, CG Docket No. 02-278 (adopted Sept. 30, 2026; released Oct. 1, 2026): docs.fcc.gov
- DA 26-12, Order extending the revoke-all waiver to January 31, 2027 (CGB, Jan. 6, 2026): docs.fcc.gov
- FCC 24-24, Report and Order and FNPRM on revocation of consent (2024): docs.fcc.gov
- 47 C.F.R. § 64.1200(a)(10): eCFR
This article is general information, not legal advice. Talk to TCPA counsel about your own program.