FCC Extends Waiver of TCPA Consent Rule Providing “Stop One Means Stop All”

Last October, the Federal Communications Commission (FCC or “Commission”) sought comments on modifying the “stop one means stop all” revocation of consent provision in its Telephone Consumer Protection Act (TCPA) rules. The FCC had previously delayed the effective date of the rule through April 11, 2026.

After accepting a slew of substantive initial comments from a variety of stakeholders (e.g., banks, utilities, pharmaceutical organizations) in response to its October 2025 request for input, the FCC has decided to further delay the effective date until January 31, 2027.

The FCC’s Consumer and Governmental Affairs Bureau (“Bureau”) acted to “allow sufficient time to review the record compiled in response” to the October 2025 request for comments on potentially modifying the rule and “to avoid imposing potentially unnecessary compliance costs on affected parties.”

More specifically, the Bureau noted that “given the possibility the Commission may modify the existing requirement, we find that good cause exists and the public interest is served by extending the waiver… to allow the Commission to fully assess the record compiled in response to this request for comment on this matter. Multiple organizations have indicated that, absent a delay, they will face significant hardship and resource burdens to comply with the rule. For example, several electric utilities report that they would need to invest ‘substantial funds, personnel resources, and time’ to modify ‘communications systems and coordinate with third-party vendors.’ A further extension of the rule’s effective date until the Commission decides whether to change the rule will avoid premature and potentially unnecessary compliance efforts and costs.”

Why January 31, 2027? The Bureau merely concluded that the 12 month extension would provide “a reasonable opportunity for the Commission to review these issues while relieving financial institutions and other businesses of the necessity to design and implement systems to comply with the rule.”

As for the “record” on the issues to be reviewed, reply comments are due by February 3, 2026. The lengthy list of initial comments to date can be found here.

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