FCC Delays Cross-Channel Consent Revocation Rule: What Businesses Need to Know

In significant news for marketers and customer engagement teams, the Federal Communications Commission (FCC) has officially delayed implementation of a key component of its recent consent revocation rules under the Telephone Consumer Protection Act (TCPA). The rule requiring businesses to honor opt-out requests across all communication channels has been postponed until April 11, 2026.

This delay follows a legal challenge by the Insurance Marketing Coalition (IMC) and aligns with the FCC’s previous delay of the one-to-one consent rules, which were simultaneously vacated by the Eleventh Circuit in January. The FCC rightly found that large and small businesses alike are having a challenging time implementing the system and process changes to enable cross-channel opt outs.

The FCC granted the delay only “to the extent that it requires callers to apply a request to revoke consent made in response to one type of message to all future robocalls and robotexts from that caller on unrelated matter.” For now, businesses should focus on the aspects of the rule that are seemingly still going into effect on Friday April 11, 2025.

What’s been delayed

Cross-Channel Consent Revocation: This provision would have required businesses to honor a consumer’s opt-out request across all communication channels—text, email, or phone—regardless of how the request was made. This aspect will now be enforced starting April 11, 2026, pending any other legal developments.

What’s still going into effect

Despite the delay of the cross-channel rule, several other key consent-related requirements are seemingly still taking effect this Friday. Please consult with your counsel to confirm which aspects may impact your business.

• Any Reasonable Method is Valid: Consumers can revoke consent through any reasonable means—such as email, customer service lines, or web forms. The burden is on the business to prove a method was not reasonable.

• 10-Day Opt-Out Processing: Companies must process opt-out requests within 10 business days, a sharp reduction from the prior 30-day window.

• Clarification Message Allowed: A single follow-up message may be sent within five minutes of receiving an opt-out, solely to clarify the scope of the revocation (e.g., marketing-only vs. all communications).Text Opt-Out Disclosure Requirement: If a user cannot opt out by replying to a text, businesses must clearly disclose this and provide alternative opt-out options.

• Informational vs. Marketing Distinction: Businesses may still send informational messages under certain exemptions, but consumers can revoke consent to marketing messages that follow those informational interactions.

What’s next?

Industry stakeholders should stay tuned as legal and regulatory reviews continue on this development. Meanwhile, it’s critical to prepare for full compliance with the delayed cross-channel rule in 2026 and ensure all other requirements are implemented this week.

DISCLAIMER: This post is for informational purposes only and does not constitute legal advice. Regulatory requirements are subject to change, and interpretations may vary. Businesses should consult their own legal counsel to assess how these changes may affect their specific operations and compliance obligations.