On September 30, 2026, the FCC adopted final changes to its TCPA consent-revocation rules. The rules take effect 30 days after they have been published in the Federal Register. This is a positive step. Organizations can honor a revocation request on a type-specific basis and keep informational and marketing calls and text activity separate. This helps consumers keep receiving the information they want while blocking what they don't.
Our partners at Mac Murray & Shuster LLP recently published a blog, FCC Finalizes New TCPA Revocation Rules, discussing what's changed and how to prepare for the new rules.
In January, we filed comments asking the Commission to protect consumer choice and not to adopt a blunt “revoke-all” approach. This order moves in that direction. Here's what changed, where we stood, and what to do next.
The update: what the FCC adopted
In short:
1. Lets callers apply a revocation to one category of informational messages, while marketing revocations still cover all marketing.
2. Lets callers designate one clearly disclosed method for consumers to revoke consent.
3. Gives financial institutions more flexibility to source numbers for fraud and security alerts.
What to do:
1. Watch for the dates.
2. Decide on a single revocation channel.
3. Map your message categories.
4. Sync opt-outs across channels and vendors.
5. Review fraud-alert sourcing (financial institutions).
6. Weigh in on the Further Notice.
Where we stood: our comments to the FCC
On January 5, 2026, Sonera filed comments in the FCC's Further Notice of Proposed Rulemaking (CG Docket Nos. 17-59, 02-278, 25-307; WC Docket No. 17-97). On revocation, our position was simple: a revoke-all rule takes choice away from consumers.
We made several points, and the final order reflects those points. It allows category-specific revocations for informational messages and keeps the full marketing opt-out. This protects consumers without forcing them to choose all or nothing.
The FCC cited our comments several times in its draft Report and Order, which the Commission adopted on September 30. It weighed our concern about consumers unintentionally opting out of communications they still want, along with input from other industry and consumer stakeholders. We thank the FCC for considering our comments and the input of all stakeholders.
Practical Guidelines
Compliance by design
Revocation rules work best when they're built into the workflow from the start. Organizations will need to ensure that consent records, category tags, and suppression lists are connected.
This is why we take part in the regulatory process. It gives us a chance to share what we see in practice, explain how proposed requirements may affect businesses and consumers, and help shape workable compliance standards.
We'll keep responding and providing input to the Public Notices, and we'll keep representing the industry's interests at the FCC.
Written by — Tammy Glover Fowler, M.S., Legal & Compliance Director, Sonera
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Mac Murray & Shuster is a nationally-recognized law firm focused on telemarketing, privacy, and other consumer protection laws. Led by a team of former regulators, they help businesses proactively manage compliance obligations, assess risk, defend against litigation, and respond to regulatory investigations and enforcement actions. You can subscribe here to receive their latest blog posts and monthly regulatory roundup newsletter.
