Topic 06

Federal Communications Commission Rulemaking

The Federal Communications Commission (FCC) promulgates rules implementing the Telephone Consumer Protection Act (TCPA). Those rules sit at 47 C.F.R. § 64.1200, and they change often.

Recent and pending actions

  1. Revocation, round two. FCC 26-67, released October 1, 2026, lets callers designate an exclusive opt-out method and makes a marketing opt-out apply to all marketing. It takes effect 30 days after its publication in the Federal Register, which had not occurred as of October 14, 2026.
  2. Revocation, round one. FCC 24-24 rules took effect April 11, 2025: revoke by any reasonable means, honored within 10 business days.
  3. One-to-one consent vacated. The U.S. Court of Appeals for the Eleventh Circuit struck the rule in January 2025. The FCC removed it effective August 29, 2025.
  4. Do-not-originate blocking. Since December 15, 2025, every voice service provider must block calls from numbers on a reasonable do-not-originate list.
  5. Artificial intelligence (AI) voices. FCC 24-17 treats AI-generated voices as artificial voices. The proposed AI disclosure rules (FCC 24-84) are pending.
  6. Further proposals. FCC 25-76 (October 2025) seeks comment on caller name branding and on eliminating the ring-time and abandonment rules. A March 2025 petition on quiet hours for texts awaits action.

The FCC's role has also changed. In McLaughlin Chiropractic Associates v. McKesson Corp. (2025), the Supreme Court held that district courts in enforcement cases interpret the statute themselves, giving the FCC's views "appropriate respect" rather than binding effect.

What this means for you

Always check the effective date and the current text in the eCFR before relying on an FCC order. The articles in this section report each order, waiver, and proposal.

The maintained guide

Federal Rules Under the Telephone Consumer Protection Act

Congress enacted the Telephone Consumer Protection Act (TCPA) and directed the Federal Communications Commission (FCC) to implement it.

Analysis and news 9

Regulatory update · Autodialers & artificial voice

FCC Imposes $120 Million Penalty on Adrian Abramovich for 96 Million Spoofed Robocalls

On May 10, 2018, the Federal Communications Commission (FCC) adopted a Forfeiture Order imposing a $120,000,000 penalty on Adrian Abramovich, personally and doing business as Marketing Strategy Leaders, Inc. and Marketing Leaders, Inc. The FCC found that he made 96,758,223 illegal spoofed robocalls during a three-month period in 2016.

Case law 3

Supreme Court · 2025

McLaughlin Chiropractic Associates, Inc. v. McKesson Corp. (2025)

In a private lawsuit or other enforcement proceeding under the Telephone Consumer Protection Act (TCPA), a federal district court is not bound by the Federal Communications Commission's (FCC) interpretation of the statute.

D.C. Circuit · 2018

ACA International v. FCC (D.C. Cir. 2018)

The D.C. Circuit reviewed a 2015 order of the Federal Communications Commission (FCC) interpreting the Telephone Consumer Protection Act (TCPA).

Research resources 4

FCC & rulemaking

Following FCC TCPA Proceedings

Most changes to federal robocall and telemarketing rules begin life as a proceeding at the Federal Communications Commission (FCC).

FCC & rulemaking

FCC Rules (47 C.F.R. § 64.1200): Research Guide

The Federal Communications Commission (FCC) implements the Telephone Consumer Protection Act (TCPA) mainly through one long regulation: 47 C.F.R. § 64.1200, titled "Delivery restrictions." This guide gives an overview of how the regulation is laid out, highlights the paragraphs that come up most often, and lists recent and pending changes as of October 14, 2026.

Primary sources

  1. 47 C.F.R. § 64.1200 (eCFR, current)
  2. FCC 26-67
  3. FCC 24-24
  4. Insurance Marketing Coalition Ltd. v. FCC, No. 24-10277 (11th Cir. Jan. 24, 2025)
  5. FCC 25-15
  6. FCC 24-17
  7. FCC 24-84
  8. FCC 25-76
  9. FCC Public Notice DA 25-216
  10. McLaughlin Chiropractic Associates, Inc. v. McKesson Corp., 606 U.S. 146 (2025)