FCC Revocation Rule 64.1200 (a)(12) -> Effective April 11
Some important news regarding the effective date for this policy. The FCC has delayed the “reasonable methods” provision of the new revocation of consent regulations until April 11, 2026, in its Order released just four days before the revocation rules were set to take effect on April 11, 2025.
In response to waiver requests from several banking and financial institutions, the FCC acknowledged that businesses need additional time to implement revocation procedures that are both cost-effective and compliant with the new rules. Implementation is particularly challenging for organizations that use multiple communication systems or must coordinate revocations across various consumer-facing business units.
Despite this limited delay, the FCC emphasized that compliance with other provisions of the new revocation rules remains mandatory starting April 11, 2025. These include amendments to sections 47 C.F.R. § 64.1200(a)(9)(i)(F) and (d)(3). The FCC has delayed implementation of this rule only as it relates to this broad application of opt-outs across unrelated communications. The rest of the new TCPA rule — including requirements to honor common opt-out keywords and process revocations within 10 business days — is still on track to go into effect on April 11, 2025.
Although the implementation deadline has been extended, it is unlikely the rules will be overturned. There is no active legal challenge, and the rules received unanimous FCC approval, consistent with the agency’s broader effort to empower consumers in choosing who may contact them.
Businesses should continue preparing for compliance by:
Updating processes to coordinate opt-outs across communication channels (e.g., calls vs. texts).
Training staff on recognizing valid revocation requests.
Setting clear parameters to identify when a call or text should be treated as a revocation.
Establishing review mechanisms to ensure opt-outs are properly tracked and honored.
This supplementary Order allows consumers to revoke their consent to receive unwanted communications, such as telemarketing calls or SMS messages, at any time and through any reasonable means. This rule is also wrapped up under TCPA and is aimed at protecting consumers from unwanted or abusive communications.
Key Aspects of the FCC Revocation Rule:
*It is recommended that you apply logic and consideration if your brand hosts multiple campaigns that are one-time, transactional and promotional in nature. Ensuring that continued engagement with the subscriber involves only messaging they wish to receive.
Please note that our US Tier 1 carrier partners already established Best Practices for aggregators like Sinch to communicate downward to our customers to implement "other" opt-out keywords, to monitor subscriber sentiment and if applicable to incorporate opt out keywords in other languages. We shared these in February 2024 as a CN they can also be found here in Community Sinch Opt-out Guide
If you have any questions please reach out to your Legal, your Sinch Account Manager or a member of the North American Compliance Team.
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