Breaking compliance news
BREAKING
FCC Robocall Consent Revocation Final Rule: The November 25, 2026 Effective Date, Category-Scoped Opt-Outs, and the Revocation Records Call Teams Must Keep
BREAKING COMPLIANCE NEWS
Published: October 27, 2026 Effective date: November 25, 2026
The FCC has published the final rule text amending 47 CFR § 64.1200. The amendments take effect November 25, 2026, superseding the previously extended January 31, 2027 date for the relevant portion of § 64.1200(a)(10). Contact-center, outreach, collections, healthcare, and financial-services teams should use the intervening period to confirm their revocation methods, disclosures, category logic, and evidence records.
This article focuses on the final rule mechanics and processing records. For the broader operational overview, see FCC Rewrites TCPA Consent Revocation: What Compliance Teams Must Change Before the Rule Takes Effect.
Direct answer
Starting November 25, callers may designate one or more FCC-listed methods as the exclusive means to revoke consent, if the methods are clearly and conspicuously disclosed. A revocation responding to an informational call or text may be limited to the specific category of informational communication addressed. A request responding to advertising or telemarketing revokes consent to all future advertising or telemarketing calls and texts from that caller. Covered requests must be honored within a reasonable time, no later than ten business days after receipt.
The amended rule also establishes a five-minute presumption for certain confirmation texts and changes the source condition for a financial institution's informational-call exemption. The rule governs telephone and text communications, not mailed notices.
Rule requirements and timing
| Requirement area | Applicability | Timing | Delivery method | Exceptions and limits | Controlling authority |
|---|---|---|---|---|---|
| Category-scoped revocation | Revocation responding to an informational call or text without advertising or telemarketing | Effective November 25, 2026 | Process the request against the specific informational category to which it was directed | A request responding to advertising or telemarketing covers all future advertising or telemarketing communications from that caller | 47 CFR § 64.1200(a)(10) |
| Exclusive designated method | Callers choosing to limit revocation channels | Disclose clearly and conspicuously on the call or in the text | Automated interactive voice or key press; qualifying reply text; or caller-designated website or telephone number | If no exclusive method is designated, process requests made by any reasonable means. Certain existing opt-out requirements remain applicable | § 64.1200(a)(10)–(11) |
| Honor period | Requests made through the applicable method | Within a reasonable time, not more than ten business days from receipt | Process and suppress through the relevant systems | The ten-business-day limit applies whether an exclusive method is designated or not | § 64.1200(a)(10)–(11) |
| Confirmation text | Text confirming a revocation request | Within five minutes for the presumption | Text must only confirm the request and contain no marketing or promotional content | A later text requires a showing that the delay was reasonable | § 64.1200(a)(12) |
| Financial-institution number source | Certain informational calls and texts under the financial-institution exemption | Effective November 25, 2026 | Number must be provided by the customer or obtained from a defined reliable source | Opt-out requests must still be honored; other exemption conditions remain | § 64.1200(a)(9)(iii)(A) |
The final rule was published October 26, 2026, as document 2026-21821, 91 FR 67214. It implements FCC 26-67 in CG Docket No. 02-278, adopted September 30 and released October 1, 2026.
Category scope depends on the communication that prompted the request
The final text allows callers to treat a revocation responding to an informational robocall or text as applying only to the specific informational category addressed. Informational means the communication contains no advertisement and does not constitute telemarketing.
The distinction matters for programs sending separate payment reminders, appointment notices, fraud alerts, or account updates. A category decision should be traceable to the communication that prompted the request. A single global suppression status does not show whether the organization correctly applied the permitted scope.
Advertising and telemarketing follow a different rule. A revocation in response to such a communication withdraws consent for all future advertising or telemarketing calls and texts from that caller. Teams should not apply the informational category limitation to those requests.
Exclusive methods require clear disclosures and functioning channels
Callers may designate one or more of three methods as exclusive:
- An automated, interactive voice or key press-activated opt-out mechanism on a call.
- A reply to an incoming text using any one of these standardized words: "stop," "quit," "end," "revoke," "opt out," "cancel," or "unsubscribe."
- A website or telephone number designated to process opt-out requests.
The caller must clearly and conspicuously disclose the designated method on the call or in the text. A text sender designating reply text as exclusive may satisfy the disclosure requirement by including at least one standardized word in each text. The sender must recognize all seven listed words as valid revocation requests.
A caller that properly designates an exclusive method is not required under this provision to process requests made through other means. A caller that does not make that designation must continue to process requests made by any reasonable means. When a consumer produces evidence of a request through a means not listed in paragraph (a)(10), the rule establishes a rebuttable presumption of revocation, absent contrary evidence, with a totality-of-the-circumstances analysis.
The final rule does not displace separate opt-out mechanisms required for certain exempted calls or advertising and telemarketing calls. Review those provisions independently before changing scripts or call flows.
For texts sent using a protocol that does not allow replies, each text must clearly disclose the technical limitation and provide reasonable alternative revocation methods. Preserve the exact message version and evidence that the alternative channel was available.
Confirmation-text timing needs a separate control
A text confirming a revocation does not violate the relevant call and text restrictions if it only confirms the request and includes no marketing or promotional information. If sent within five minutes after receipt, it is presumed to fall within the consumer's prior express consent. If sent later, the sender must be able to show that the delay was reasonable.
A confirmation process should therefore record the request-received timestamp, confirmation-send timestamp, message content, and delivery status. Keeping the confirmation free of promotions preserves the limited scope of this provision.
Evidence-file template for revocation processing
The FCC amendments do not prescribe a new field-by-field revocation register. The following controls are practical evidence measures, not a representation that each field is separately mandated by the rule. They help demonstrate the communication context, processing decision, and completion date.
| Record field | Evidence to retain |
|---|---|
| Request event | Received date and time, receiving channel, called number, request wording, and associated call or text |
| Communication context | Message or script version, communication category, and whether it contained advertising or telemarketing |
| Consent connection | Relevant consent record, consent event date, and category or categories tied to that event |
| Scope decision | Category affected, decision rationale, and processing owner |
| Designated method | Method selected, effective date, and the call or text disclosure shown to the recipient |
| Processing completion | Suppression or status-change timestamp, honor date, and any exception or escalation |
| Confirmation text | Content, send timestamp, elapsed time from receipt, and delivery evidence |
| Supporting material | Call recording or system log, message record, website submission, and audit history, where available |
The timeline should make it possible to compare receipt with the ten-business-day maximum and, if a confirmation text was sent, with the five-minute presumption. Access controls and change history help preserve the original request and prevent later status edits from obscuring the event.
Financial-institution number records
For the specified informational-call exemption, a financial institution may use a wireless number provided by the customer or obtained from a reliable source. The final rule defines a reliable source as a number supplied by a spouse or other family member authorized to be on the account, obtained when the customer calls the institution, or included in records obtained from another financial institution.
Maintain evidence of the number's source and its relationship to the relevant account and communication. The institution must still honor opt-out requests. The amendment changes the number-source condition, not the other applicable terms of the exemption.
Implementation checklist before November 25
- Inventory communication programs and map informational, advertising, and telemarketing categories.
- Select whether to designate one or more exclusive revocation methods.
- Confirm that disclosures appear in the correct call and text versions.
- Test every designated channel, including recognition of all standardized reply words.
- Update processing logic to distinguish informational categories from advertising and telemarketing.
- Track receipt and completion timestamps against the ten-business-day ceiling.
- Test confirmation-text timing and remove marketing from confirmation content.
- Document the source of wireless numbers used under the financial-institution exemption.
- Preserve approved scripts, message versions, system logs, and change history.
This evidence discipline parallels electronic notice consent controls, although the FCC rule addressed here concerns telephone and text communications, not mailed notices. Related process guidance is available in Electronic Service Requirements: When Courts and Rules Allow Notice by Email.
Sources
- Federal Register final rule, document 2026-21821, 91 FR 67214
- Official Federal Register PDF at GovInfo
- FCC Report and Order, FCC 26-67
- 47 CFR Part 64
This article provides general compliance information, not legal advice.