Last verified: 2026-09-03 · FCC DA 26-12, DA 25-312, FCC 24-24, eCFR
The revoke-all rule is not in effect yet.
It has been delayed twice. Most compliance guidance still cites a date that has already passed. Here is what is enforceable today, what is not, and when that changes.
Compliance date 2027-01-31 · was 2025-04-11 · DA 26-12 Order ↗
| Rule | Citation | Status | Key date | Source |
|---|---|---|---|---|
| Revocation by any reasonable method; no exclusive means | 47 CFR 64.1200(a)(10) | In effect | 2025-04-11 | FCC 24-24 ↗ |
| Revocation requests honored within 10 business days | 47 CFR 64.1200(a)(10) | In effect | 2025-04-11 | FCC 24-24 ↗ |
| Rebuttable presumption for revocation by reply, voicemail or email | 47 CFR 64.1200(a)(11) | In effect | 2025-04-11 | FCC 24-24 ↗ |
| Internal do-not-call requests honored within 10 business days | 47 CFR 64.1200(d)(3) | In effect | 2025-04-11 | FCC 24-24 ↗ |
| AI-generated voices are "artificial" voices under the TCPA | 47 USC 227(b)(1)(A) | In effect | 2024-02-08 | FCC 24-17 ↗ |
| Revocation must apply across all unrelated matters | 47 CFR 64.1200(a)(10) | Delayed | 2027-01-31 | DA 26-12 ↗ |
| One-to-one consent for lead generators | former 47 CFR 64.1200(f)(9) | Vacated | 2025-01-24 | 11th Cir. / DA 25-621 ↗ |
| FNPRM on the scope of the revocation rule | FCC 25-76, CG Docket 02-278 | Pending | — | FCC 25-76 ↗ |
The delay applies to one narrow construction only. Everything below has been enforceable since 2025-04-11 and is unaffected by the waiver — DA 26-12 says so explicitly. Treating the whole order as postponed is the most common and most expensive misreading of this rule.
Revocation by any reasonable method; no exclusive means
A consumer may revoke consent by any reasonable method. A sender may not designate an exclusive means of revocation, and may not treat a revocation as invalid because it used the "wrong" channel or wording.
47 CFR 64.1200(a)(10) · FCC 24-24 ↗
Revocation requests honored within 10 business days
Once a revocation request is received, it must be honored within 10 business days. This obligation is live now and is independent of the waived cross-subject rule.
47 CFR 64.1200(a)(10) · FCC 24-24 ↗
Rebuttable presumption for revocation by reply, voicemail or email
Revocation sent by text reply, voicemail or email to a number or address the sender made available creates a rebuttable presumption that consent was revoked.
47 CFR 64.1200(a)(11) · FCC 24-24 ↗
Internal do-not-call requests honored within 10 business days
Internal DNC requests must be recorded and honored within 10 business days of receipt.
47 CFR 64.1200(d)(3) · FCC 24-24 ↗
AI-generated voices are "artificial" voices under the TCPA
A declaratory ruling confirming that calls using AI-generated or voice-cloned audio are "artificial or prerecorded voice" calls, and therefore require prior express written consent for marketing. There is no separate federal AI-disclosure mandate yet -- that NPRM (FCC 24-84) remains pending.
47 USC 227(b)(1)(A) · FCC 24-17 ↗
Second waiver. The compliance date moves again, to January 31, 2027. The order is explicit that it does not disturb any other revocation rule already in force.
DA 26-12 ↗The Commission issues a Further Notice asking whether the cross-subject requirement should be modified or replaced outright.
FCC 25-76 ↗The FCC removes the vacated one-to-one consent text from the CFR. Consent standards revert to what they were before the rule.
DA 25-621 ↗Four days before it was due to take effect, the Bureau waives the cross-subject revocation requirement for one year, to April 11, 2026, on request from banking and lending trade associations. The rest of the revocation rules take effect on schedule.
DA 25-312 ↗The Eleventh Circuit vacates the one-to-one consent rule in Insurance Marketing Coalition v. FCC, holding the FCC exceeded its authority. Mandate issued April 30, 2025.
11th Cir. No. 24-10277 ↗The Commission adopts the revocation order. Compliance date for the revocation rules is set at April 11, 2025.
FCC 24-24 ↗Plan for it. The Consumer and Governmental Affairs Bureau extended this date twice on delegated authority — a bureau-level order, no Commission vote, issued four days before the deadline the first time. A Further Notice asking whether to modify or replace the requirement outright (FCC 25-76) closed its reply window on 2026-02-03 and the Commission has not acted since.
Build your revocation handling so it does not depend on the date. The obligations already in force are the ones that get you sued this year.