In January 2024, the Federal Communications Commission (“FCC”) released a notice of proposed rulemaking (“NPRM”) regarding changes to consumers’ ability to revoke consent for further texts or calls under the Telephone Consumer Protection Act (“TCPA”).
The FCC has finally set the date of enforcement for these new requirements: April 11, 2025. The full order is available here.
Currently, the TCPA implementing regulations require that a “do-not-call” request be honored “within a reasonable time from the date such request is made [and] . . . [t]his period may not exceed 30 days from the date of such request.” 47 C.F.R. § 64.1200(d)(3).
Beginning April 11, 2025, company-specific “do-not-call” requests are required to be honored as soon as practicable, not to exceed 10 days from the date of such request.
You still should implement the requests as quickly as reasonable- a time period that may be shorter than 10 days. You should review your procedures and create a record, in advance of any complaint, evaluating your do-not-call procedures to ensure this time is as short as reasonable. I would be happy to help with this review if you like.
