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Constraintconstraint.tcpa-revoke-all-universal-opt-out

TCPA Revoke-All Universal Opt-Out Rule

FCC rule (47 CFR § 64.1200(a)(10)) requiring any opt-out communication from a consumer — regardless of channel — to revoke all consent for robocalls and robotexts from that caller. Originally adopted 2024, compliance deadline extended by FCC order to January 31, 2027. CDP and composable activation stacks routing messages across SMS, email, and push must implement cross-channel suppression propagation before the deadline: one STOP message to any channel must suppress the profile across all downstream activation destinations.

confidence 82%v1reviewed May 18, 2026tcpa, fcc, revoke-all, sms, opt-out, consent-revocation, cross-channel-suppression, compliance-deadline, activation-gate

TCPA Revoke-All Universal Opt-Out Rule

The FCC's Revoke-All rule (47 CFR § 64.1200(a)(10)) requires that any opt-out request from a consumer — via any reasonable means — revoke all consent for automated calls and texts from that caller across all communication types. Adopted in 2024, originally effective April 2025; a January 6, 2026 FCC order extended the compliance deadline to January 31, 2027.

What the Rule Requires

A consumer who texts STOP to an SMS campaign, says "stop calling me" on a voice call, or clicks "unsubscribe" in an email has exercised their right to revoke consent from that sender across all channels and all campaign types. Callers may not continue robocalling or robotexting a consumer who has opted out via any reasonable channel, even if that opt-out arrived through a different channel than the one being used to contact them.

CDP and Activation Stack Implications

Cross-channel suppression propagation. In a multi-destination activation architecture (email via Braze or Salesforce Marketing Cloud, SMS via Twilio, paid media via Meta Custom Audiences), a single opt-out event received at any destination must propagate to the unified suppression table and suppress the profile from all downstream destinations before the next send window.

Composable stack non-triviality. For Reverse-ETL stacks (Hightouch, Census, GrowthLoop), cross-channel suppression requires:

Stacks where each destination manages its own suppression list independently will fail this requirement when an opt-out received at one destination is not propagated to others.

Packaged CDP implementations. CDPs with native cross-channel consent management (AEP Consent Fields, Segment Protocols with consent enforcement, Braze Global Subscription Groups) must confirm their architecture covers the Revoke-All scenario — propagating any opt-out received at any channel to all other active channels — not only STOP keyword handling for the specific channel that received the opt-out.

Relationship to constraint.tcpa-prior-express-written-consent-sms

That constraint governs obtaining consent before sending. This constraint governs propagating revocation of consent once any opt-out is received. Both apply simultaneously to organizations with multi-channel marketing programs. An organization can be fully PEWC-compliant at time of consent acquisition and still violate the Revoke-All rule if its suppression propagation architecture is not updated before January 31, 2027.

Sources

Related

This node →

  • related-toconstraint.tcpa-prior-express-written-consent-sms— TC-78. Sibling TCPA constraints: PEWC governs consent acquisition; Revoke-All governs propagation of consent revocation across channels. Both apply simultaneously to multi-channel SMS programs.
  • governsmodality.sms— TC-78. The Revoke-All rule governs SMS opt-out propagation: STOP to one sender's SMS must suppress that profile across all of that sender's downstream channels.
  • governsmodality.email— TC-78. Email unsubscribe is a 'reasonable means' of opt-out under the Revoke-All rule; clicking unsubscribe in email must propagate to suppression of SMS and push for the same sender.
  • governsmodality.push— TC-78. Push notification opt-out (in-app unsubscribe, OS-level disable) is a 'reasonable means' under the Revoke-All rule and must propagate to the sender's other active channels.

← Referenced by

  • governed-byarchetype.salesforce-ecosystem-enterprise-evaluating-cdp— OC-049. Salesforce ecosystem enterprises running Marketing Cloud Next use multi-channel SMS, email, and push activation across multiple destinations. The TCPA Revoke-All rule (47 CFR § 64.1200(a)(10), deadline January 31, 2027) requires cross-channel opt-out propagation: a single STOP to any channel must suppress the profile across all active Marketing Cloud Next channels and any composable-layer destinations (Hightouch, Fivetran Activations syncs). Architects evaluating composable augmentation must include Revoke-All suppression propagation in the CDW profile model design.