FCC Replaces “Revoke All” Rule and Permits Callers to Designate an Exclusive Revocation Method

On October 1, 2026, the Federal Communications Commission (FCC or Commission) released its (Order and FNPRM, respectively) amending the revocation rules in the Telephone Consumer Protection Act (TCPA) regulations. The Order overhauls the FCC’s prior “Revoke All” rule by allowing callers to apply an opt-out request to the category of informational robocalls to which the request is directed rather than to all robocalls. Order at ¶ 10. Also, for the first time, callers may designate an exclusive method of revocation to avoid the default rule that all revocation requests made “using any reasonable method” must be honored. Order at ¶¶ 15–16; App. A, 47 C.F.R. § 64.1200(a)(10). The FCC also included an accompanying FNPRM seeking comment on whether it should implement a shorter revocation deadline, mandate two-way texting, require a revoke-all option, expressly permit confirmatory calls and texts to clarify categorical opt-outs, or issue rules clarifying the impact of opt-outs on a caller’s other divisions, lines of business and/or affiliates. Order at ¶¶ 30–36, 39.

Background

In 2024, the FCC providing that consumers may revoke consent by “any reasonable means” and requiring callers to treat an opt-out from one type of robocall as an opt-out from all robocalls requiring consent, among other things. Most of those rules . The “Revoke All” provision, however, was until April 11, 2026, and a subsequent waiver extended its effective date to January 31, 2027. In 2025, the FCC also issued an seeking, among other things, input on potential revisions to the revocation rules. FNPRM at ¶¶ 101–104.

On September 9, 2026, the FCC issued a for consideration at its September 30, 2026 open meeting, where it was adopted with editing privileges. The next day, the FCC released its reflecting revisions to the requirements for text opt-out disclosures and expanding topics in the accompanying FNPRM to include confirmation calls and texts. Order at ¶¶ 17, 38.

The New Rules

Category-specific revocation. Callers may now interpret a revocation request made in response to an informational call or text as applying only to that specific category of informational robocalls, rather than to all robocalls from the caller. App. A, 47 C.F.R. § 64.1200(a)(10). The FCC explained, for example, that under the prior rule, a consumer who opted out of payment reminders would also cut off fraud alerts, multi-factor authentication, appointment reminders and outage notices. Order at ¶ 11. For these purposes, telemarketing is treated as a single category: an opt-out in response to any marketing call or text revokes consent to all future telemarketing calls and texts from that caller. Order at ¶ 14.

Exclusive revocation methods. Callers may designate one or more of the following as the exclusive means to revoke consent:

• An automated, interactive voice or key press-activated opt-out mechanism on a call;
• Replying to an incoming text using any one of the standardized words “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel” or “unsubscribe”; and/or
• A website or telephone number designated by the caller to process opt-out requests.
• App. A, 47 C.F.R. § 64.1200(a)(10)(i)–(iii).

The designated method must be clearly and conspicuously disclosed on the call or in the text. App. A, 47 C.F.R. § 64.1200(a)(10). Text senders that designate a reply text as the exclusive method may satisfy this requirement by including just one of the standardized words (e.g., “stop”) in each message but must still honor a revocation made using any of the standardized words. Order at ¶ 17; App. A, 47 C.F.R. § 64.1200(a)(10). Callers that designate an exclusive method need not process revocation requests made by any other means, whereas callers that do not specify an exclusive revocation method must continue to honor requests made by any “reasonable means.” App. A, 47 C.F.R. § 64.1200(a)(11). The new rules do not change the opt-out mechanisms already required for calls made under an exemption or that include an advertisement or constitute telemarketing. Order at ¶ 19.

Fraud alert exemption. Financial institutions relying on the fraud alert exemption may now call or text wireless numbers obtained from a “reliable source” rather than only numbers the customer provided directly. Order at ¶ 20; App. A, 47 C.F.R. § 64.1200(a)(9)(iii)(A). A “reliable source” is a number supplied by an authorized family member on the account, obtained when the customer calls the institution or included in records obtained from another financial institution. Id.

Takeaways for Businesses

• Designate an exclusive revocation method. Unless and until a business specifies an exclusive method for revocation, it must continue to honor any revocations made by “reasonable means,” including those not made by one of the three recognized revocation methods under the regulations. Such revocations create a rebuttable presumption that consent was revoked, and the burden is on the caller to prove otherwise. App. A, 47 C.F.R. § 64.1200(a)(11). Businesses that wish to limit how consumers revoke consent should adopt one of the three methods permitted under the amended regulations and configure their systems to process requests through them. Order at ¶¶ 15–17. The “reasonable means” standard has been used to manufacture lawsuits, so designating a method may help limit litigation exposure. Order at ¶ 17 and n. 45.
• Disclose the designated method. The benefit of an exclusive method depends on clear and conspicuous disclosure on each call or in each text; for reply-text opt-outs, disclosing one standardized word such as “stop” is sufficient. Order ¶¶ at 16–17; App. A, 47 C.F.R. § 64.1200(a)(10).
• Define informational message categories. Category-specific revocation works best when message types (e.g., fraud alerts, appointment reminders, payment reminders) are clearly delineated. Order at ¶ 11.
• Prepare for further changes. A shorter revocation deadline, mandatory two-way texting and a required revoke-all option remain under consideration. Order at ¶¶ 30–36. The FCC also seeks comment on allowing confirmation calls or texts, including texts asking which category of messages the consumer intended to opt out of. Order at ¶ 39. The deadline to submit comments to the FNPRM and weigh in on these issues will be 30 days after publication in the Federal Register.

Effective Date

The new rules will become effective 30 days after publication in the Federal Register. Order at ¶ 24. As of the date of this client alert, the Order has not yet been published in the Federal Register. The Order is attached.