FCC Delays TCPA Revoke-All Rule Effective Date to January 31, 2027
Source: Burr & Forman LLP — TCPA Blog
Published: January 7, 2026
Key Facts
The Revoke-All Rule (47 CFR § 64.1200(a)(10)): Adopted February 16, 2024. Requires callers to treat a consent revocation made in response to any one type of robocall or robotext as applying to all future calls and texts from that caller, regardless of topic or relationship.
Compliance deadline timeline:
| Date | Status |
|---|---|
| February 16, 2024 | Rule adopted |
| April 11, 2025 | Original effective date |
| April 11, 2026 | First extension |
| January 31, 2027 | Current effective date (FCC order, January 6, 2026) |
Rationale for second extension: FCC is reviewing comments on a 2025 Further Notice of Proposed Rulemaking asking whether the revoke-all requirement should be modified to allow consumers more granular (per-category) opt-out control rather than forced universal opt-out.
What remains active: Callers must still honor consent revocation requests made through reasonable methods. Keyword opt-out mechanisms (standard STOP/UNSUBSCRIBE handling) remain required under existing rules.
Relevance to KG
- Grounds a new candidate constraint node for the Revoke-All requirement (distinct from one-to-one consent, which was eliminated).
- Relevant to [[constraint.tcpa-prior-express-written-consent-sms]] — the Revoke-All rule adds a universal opt-out propagation obligation once effective (January 31, 2027). CDP activation pipelines need to propagate opt-outs across all campaign types when one revocation event occurs.
- Draft candidate: constraint.tcpa-revoke-all-universal-opt-out (see web-refresh.md for Technical Reviewer).