By: Jeffrey Backman, Esq. and Roy Taub, Esq.
On January 6, 2026, the Federal Communications Commission (“FCC”) released an Order addressing its revocation of consent rules, providing temporary relief to callers navigating the increasingly complex TCPA compliance landscape. The Order, DA-26-12A1, extends a previously issued waiver related to Section 64.1200(a)(10) of the Commission’s rules.
Under the existing rule, callers are generally required to honor a consumer’s request to revoke consent through any reasonable means. The FCC’s revocation framework has raised significant concerns for businesses because of its potential requirement that a revocation request made in response to one type of informational message must be treated as revoking consent for all future robocalls and robotexts from that caller, even if those future messages are regarding unrelated matters.
In its January 6 Order, the FCC clarified that it is extending the waiver of this requirement. Specifically, the Commission stated that it would delay enforcement of the rule to the extent it requires callers to treat a revocation of consent tied to one informational message as universally applicable to all future automated communications from the caller. The FCC found that “good cause exists” to extend the effective date of this requirement until January 31, 2027.
The extension is intended to allow the FCC sufficient time to review the record developed in response to a recent Further Notice of Proposed Rulemaking and to avoid imposing potentially unnecessary compliance costs on affected parties. The Commission acknowledged industry concerns regarding operational feasibility, technological limitations, and the risk of overbroad consent revocation obligations.
Click here to sign up to receive Greenspoon Marder’s TCPA blog and stay informed on the latest developments and insights.
