As we approach the end of the first quarter of the year, it is a good time to take a look at two recent FCC actions that could affect the calling industry in 2026 and beyond.
Below we take a deeper dive into those actions. But here is a brief summary:
- The effective date for the FCC’s Revoke-All Rule has been delayed to January 31, 2027, and the FCC may modify that rule.
- The FCC has proposed new caller ID requirements that, if adopted, could require callers to obtain “verified names.”
FCC Delays Effective Date of Revoke-All Rule
In 2025, the FCC stayed the effective date of its Revoke-All Rule to April 11, 2026. Then on January 6, 2026, the FCC stayed the effective date of that rule to January 31, 2027.
This second stay provides those in the calling industry with another year to prepare for the impact of that rule. As part of its order delaying the effective date, the FCC indicated it may modify the Revoke-All Rule. We’ll be keeping an eye out for any such modification.
What Is the Revoke-All Rule?
The Revoke-All Rule applies to 47 U.S.C. 227(b)(1)(A) and (B) calls: non-emergency calls, made without the called party’s consent, that utilize an autodialer or artificial or prerecorded voice.
As stated by the FCC, the Revoke-All Rule will require “callers to treat a request to revoke consent made by a called party in response to one type of information messages as applicable to all future robocalls and robotexts from that caller on unrelated matters.”
The exact language of the rule is: “If a called party uses any such method to revoke consent, that consent is considered definitively revoked and the caller may not send additional robocalls and robotexts.”
Example Scenario
Under the current wording, here is an example of how the rule will work: A consumer provides their consent to receive prerecorded-marketing calls and prerecorded-fraud-alert calls from their bank.
Later, the consumer decides they no longer want to receive the bank’s prerecorded-marketing calls, and tells the bank to “stop calling me.”
Unless the consumer provides a clear indication that that consent-revocation request only applies to the bank’s prerecorded-marketing calls, the bank has to also apply the consumer’s consent-revocation request to the prerecorded-fraud-alert calls—despite the fact that the consumer never intended to revoke their consent to receive those calls.
It is not certain whether the FCC will actually modify this rule or delay its effective date again. In the meantime, those that make non-emergency ATDS or prerecorded-voice calls should use this additional time to implement modifications to their processing of consent-revocation requests to be compliant with the current version of the rule.
FCC Proposes New Caller ID Requirements
On October 29, 2025, the FCC issued a notice of proposed rulemaking in which it proposed new caller ID requirements.
Specifically, the FCC is proposing:
- Requiring terminating voice service providers to transmit a caller’s verified name whenever they transmit an indication that the call received an A-level attestation;
- Requiring originating providers to employ reasonable measures to verify the accuracy of the caller ID information they transmit; and
- Requiring voice service providers to identify calls that originate from outside the U.S., which will result in the called party receiving an indicator about the call originating from outside the U.S.
The FCC believes that such requirements will help consumers make better informed decisions about whether to answer a call or not. It theorized that these requirements will also lead to higher answer rates and engagement.
The comment and reply comment deadlines were January 5, 2026 and February 3, 2026, respectively. The FCC has yet to address those comments. It is important for callers to keep an eye out for any future FCC action concerning these proposed rules, as it may require action on the part of callers in relation to obtaining a verified name.
Key Takeaways
With the Revoke-All Rule set to become effective on January 27, 2027, callers that utilize prerecorded calls should use the time between now and then to make any necessary modifications to their processing of consent-revocation requests.
With Readymode, you can import, export, filter and edit your do-not-call list—all in the same platform you use for outbound calling.
If you’re curious how Readymode can support your outbound team, book a free demo to learn more.
This article is only offered for informational purposes; it is not legal advice. Please consult a qualified attorney for your specific compliance needs.
Joe Bowser
Joe Bowser is a partner at Roth Jackson. He has been practicing communications and marketing law for two decades. He advises and defends calling and SMS platform providers (like Readymode), carriers/VoIP providers, and heavy users of those services in their wide range of compliance needs. In his spare time, you can find him taking his boys to their sports, getting in a workout of his own, or catching an Arsenal match.
