By: Jeffrey Backman, Esq., Roy Taub, Esq., and Jacob Mars, Esq.
The Federal Communications Commission issued an order (DA-26-12A1) giving businesses additional time to prepare for an important change to the Telephone Consumer Protection Act (“TCPA”) rules governing consumer consent and revocation for robocalls and robotexts. Issued January 6, 2026, the Order extends the effective date of a new, broader consent-revocation requirement until January 31, 2027. While the extension provides businesses with more time, it does not eliminate the underlying compliance obligations or the need to maintain effective processes for honoring consumer opt-outs.
The FCC’s rules address how consumers can revoke consent to receive automated calls and text messages. Under a new requirement first announced on February 16, 2024, and initially set to go into effect on April 11, 2025, a consumer’s revocation could apply not only to the specific type of communication involved but also to future robocalls and robotexts from the same caller, including communications about unrelated matters. For businesses, this can create a significant operational challenge. Consider a customer who receives an automated appointment reminder and responds with “STOP.” Under the broader framework, that revocation could affect the company’s ability to send other automated communications to that customer, such as marketing messages or notifications about unrelated services. The challenge becomes even greater for organizations with multiple brands, departments, databases, communication platforms, or third-party vendors.
The FCC recognized that implementing the broader requirement could create substantial technical and operational challenges and that businesses may need to connect systems that historically managed consent and opt-outs separately. The FCC’s extension provides additional time to consider these concerns and evaluate whether changes to the rule are appropriate. Importantly, the January 31, 2027 date is an extension, not a repeal. Businesses should continue to monitor FCC developments because the final regulatory framework could change. Rather than waiting until 2027, organizations that rely on automated calls and texts should use the additional, valuable time to prepare and strengthen their consent-management practices. Organizations that use that time to build centralized, auditable, and flexible consent-management processes will be better positioned to comply with the evolving TCPA framework.
Although the deadline has moved, the need for effective consent management remains.
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