The eight things you need to know about the new revocation rules
With the new revocation rules on the horizon, businesses that rely on calls and text messages requiring consent must adapt to remain compliant. These updates are designed to protect consumer rights while also providing clear guidance for companies on how to handle revocation requests properly.
Latest update: FCC delays crucial part of the new revocation rule
The FCC has announced a one-year delay in enforcing a key part of the TCPA’s updated revocation rules. Originally set to take effect on April 11, 2025, the provision requiring businesses to treat a revocation of consent as applying to all future robocalls and texts from the same sender – regardless of message type – has now been postponed until April 11, 2026.
This delay gives businesses more time to prepare for the broader application of opt-out requests. However, other updates to the rule are still going live as scheduled, including the requirement to:
- Accept revocations via any reasonable method.
- Honor Do Not Call (DNC) requests within 10 business days.
While scope-related logistics are on hold, companies must still be ready to handle revocations quickly and clearly.
What you need to know
Troutman Amin associate attorney John Henson has outlined eight critical points that businesses need to understand about the upcoming revocation rules.
- Part of the new revocation rules will go into effect on April 11, 2025. The rest of it will go into effect on April 11, 2026.
- New revocation rules only apply to calls or text messages that need consent.
- All reasonable revocations of consent must be honored.
- All reasonable revocation requests should be honored within 10 business days.
- The use of any other means (phone call, text, email, etc.) to revoke consent creates a rebuttable presumption that the consumer intended to revoke consent.
- The effect of revocation of consent depends on the messaging the consumer is opting out of (marketing or informational).
- Sellers can send a one-time confirmation text to ensure consumers are unsubscribing from the correct type of communications.
- Failure of a consumer to respond to a confirmation text should be treated as confirmation of the opt-out.
ActiveProspect reached out for further comments:
“The FCC’s revocation rules impact businesses more than the 1:1 consent rule was ever going to impact businesses,” Henson said. “This is especially true for enterprise-sized businesses or businesses with multiple independently operating units. The ability for a consumer to revoke consent using any reasonable method means businesses have to understand not only how they are contacting consumers, but how consumers could potentially contact them.”
With Henson’s expertise in compliance, businesses should take these insights seriously and prepare now before the rules go into effect in April 2025.
Why these changes matter
These new revocation rules are a big deal for businesses that use phone calls and text messaging for marketing. Non-compliance could lead to lawsuits, fines, and reputational damage. Companies should take proactive steps to:
- Review their consent and opt-out policies
- Train employees on recognizing revocation requests
- Update systems to process opt-outs within 10 business days
- Clearly distinguish marketing vs. informational messaging
Are you ready for the new revocation rules? If your business relies on calls and text messaging, now is the time to bolster compliance efforts. Don’t wait until the deadline – start preparing for these changes today!
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