FCC Proposes Amendments to TCPA Consent Revocation Rules; Proposed Changes to DNC Rules Deleted from Final Text

On October 29, 2025, the Federal Communications Commission (FCC) released a Further Notice of Proposed Rulemaking (FNPRM) reconsidering certain Telephone Consumer Protection Act (TCPA) consent revocation rules. This action follows the agency’s ongoing “Delete, Delete, Delete” initiative aimed at eliminating outdated regulations and clearing a backlog of petitions, 13 of which date from 2012 to 2021. The FNPRM was unanimously adopted by the Commission on October 28, 2025 and published with key amendments.

Universal “Stop-One = Stop-All” Rule

The FCC’s previously adopted rule requiring that a single revocation of consent apply to all future calls and texts from a business had previously been delayed until April 11, 2026. In its new FNPRM, the Commission makes clear it does not intend to let the rule take effect in its current form. Instead, the agency seeks comment on how to modify the rule to balance consumers’ ability to stop unwanted calls, with their interest in continuing to receive desired communications, such as healthcare reminders or fraud alerts. The Commission emphasized that it intends “to resolve this issue in a timely fashion” and delegated authority to the Consumer and Governmental Affairs Bureau to extend the delay deadline further, if necessary. Interestingly, this final decision was a change from the draft order that sought comment on “eliminating” the rule in its entirety.

Methods of Revocation

The Commission also addressed the “reasonable means” standard, which currently requires callers to honor revocation requests communicated through any reasonable channel. Citing ambiguity and compliance challenges, the FCC is considering whether to allow businesses to designate specific opt-out mechanisms (e.g., prescribed keywords, web portals, or phone lines). This shift could reduce uncertainty while still preserving meaningful consumer choice.

Internal Do-Not-Call (DNC) Lists

While an earlier draft suggested eliminating the requirement that companies maintain internal do-not-call lists for five years, the final NPRM released today does not include this proposed change. Businesses should continue to track and honor internal do-not-call requests for the full five-year period.

Comment Period and Industry Engagement

The 30-day comment period begins with publication of a summary in the Federal Register, followed by a reply comment period, the timing of which will be clarified by the FCC. This is a critical opportunity for businesses and trade associations to provide input on how revocation rules should be structured to avoid overbreadth, reduce compliance burdens, and protect consumers from losing important communications.

Bottom Line

The FCC has signaled that the universal “stop-all” rule is unlikely to survive in its present form. Businesses should prepare for a more tailored revocation framework while continuing to meet existing TCPA and DNC obligations.