FCC Extends Compliance Deadline for “Revoke All” Rule

On Jan. 6, 2026, the Federal Communications Commission’s (FCC) Consumer and Governmental Affairs Bureau issued an order extending the effective date of a key provision under the Telephone Consumer Protection Act (TCPA). The rule at issue (embodied in section 64.1200(a)(10), commonly called the “revoke all” rule) requires callers to treat a consumer’s revocation of consent, made in response to one type of call or message, as applying to all future robocalls and robotexts from that caller on unrelated matters. The FCC adopted the revoke all rule in 2024.

Originally scheduled to take effect in April 2025, the rule was first delayed until April 2026 to give businesses time to adjust their systems. Now, the bureau has pushed the compliance deadline further to Jan. 31, 2027. The extension comes amid ongoing FCC consideration of whether to eliminate or modify the rule, following concerns raised by financial institutions, utilities and other businesses. Consumer groups have also expressed interest in revisiting the rule. These stakeholders have argued the rule as written would be difficult to implement, and the broad scope of the rule risks blocking urgent messages that consumers may still want and need for their financial security.

The FCC found that good cause exists to avoid imposing unnecessary compliance costs while it continues to review stakeholder comments and evaluate potential revisions to the rule. Importantly, this waiver applies only to the portion of the rule requiring revocation to cover all future communications from the caller. Other TCPA obligations regarding revocation of consent remain unchanged.

Businesses should use this additional time to monitor the FCC’s rulemaking process and prepare for possible changes before the new compliance deadline. Please contact the authors of this alert to learn more about this rulemaking and its implications.

THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING THE FCC EXTENDING THE COMPLIANCE DEADLINE OF THE REVOKE ALL RULE. THE CONTENTS OF THIS DOCUMENT ARE NOT INTENDED TO PROVIDE SPECIFIC LEGAL ADVICE. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS DOCUMENT OR IF YOU NEED LEGAL ADVICE AS TO AN ISSUE, PLEASE CONTACT THE ATTORNEYS LISTED OR YOUR REGULAR BROWNSTEIN HYATT FARBER SCHRECK, LLP ATTORNEY. THIS COMMUNICATION MAY BE CONSIDERED ADVERTISING IN SOME JURISDICTIONS.