To meet this requirement, businesses may allow consumers to affirmatively select which sellers they consent to hear from or provide links to separate consent forms for each business requesting permission to contact them.

New Consent Revocation Rules

Another change takes effect on April 11, 2025, when the FCC’s new consent revocation rules for robocalls and robotexts are implemented. These rules allow consumers to revoke prior consent through any reasonable method, and marketers may not designate an exclusive means for revocation. Reasonable methods include replying “stop,” “quit” or similar terms to incoming texts, using automated voice or opt-out replies, or submitting a message through a website provided by the caller.

Marketers must honor revocation requests within a reasonable timeframe, not exceeding 10 business days. After that period, no further robocalls or robotexts requiring consent may be sent to the consumer.

Preparing for Compliance

To comply with the January 27, 2025, one-to-one consent rule and the April 11, 2025, consent revocation rule, lead generators and businesses that use or facilitate robocall and robotext communications should:

• Review their current consent and revocation practices.
• Ensure compliance by updating policies before the deadlines.
• Examine where consumer leads are being obtained and adjust policies for using this information to meet the new requirements.

This advisory provides only a summary of the upcoming changes to the Telephone Consumer Protection Act.