FCC Adopts New TCPA Consent Revocation Rule: Informational Opt-Outs Narrow, Telemarketing Revoke-All Stays

FCC Adopts New TCPA Consent Revocation Rule: Informational Opt-Outs Narrow, Telemarketing Revoke-All Stays

The FCC adopted FCC 26-67 on September 30, 2026, rewriting TCPA consent revocation. Once effective, callers may read an opt-out from an informational call narrowly, while an opt-out from a marketing call or text still reaches all of that caller's advertising and telemarketing. The rules are not yet in effect.

Information last verified on October 8, 2026. This is a developing story; we update it as the record changes.

Jurisdiction scope: This article covers a federal rulemaking by the Federal Communications Commission under the Telephone Consumer Protection Act, 47 U.S.C. 227, and the rules at 47 CFR 64.1200. It applies nationwide to callers and texters subject to those rules. It does not address state telemarketing or mini-TCPA statutes, which can impose stricter requirements, and it is not a description of any pending private lawsuit.

What Happened

The Federal Communications Commission adopted FCC 26-67 on September 30, 2026, and released the full text on October 1, 2026. The item is captioned Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, and it carries CG Docket No. 02-278, the Commission's long-running TCPA docket.

It is two documents in one. The Report and Order amends four provisions of 47 CFR 64.1200: paragraphs (a)(9)(iii)(A), (a)(10), (a)(11) and (a)(12). The Further Notice of Proposed Rulemaking asks for comment on five further subject areas, none of which is law and any of which the Commission may never adopt.

The cover page records that the item issued "By the Commission: Chairman Carr and Commissioner Trusty issuing separate statements." The ordering clauses rest the action on sections 1 through 5 and section 227 of the Communications Act of 1934, as amended, 47 U.S.C. 151 through 155 and 227 (paras. 27 and 49).

Paragraph 51 also grants, in part, a petition for reconsideration the American Bankers Association filed on August 10, 2015, which is where the fraud-alert change comes from.

The Report and Order answers questions the Commission put out in its 2025 TCPA Further Notice (paras. 4, 7 and 9): whether to narrow the revoke-all rule, whether to allow an exclusive revocation method, and whether to loosen the bank fraud-alert condition. A separate joint letter filed June 30, 2026 by the American Bankers Association, the National Consumer Law Center and ACA International (CG Docket No. 02-278) supplies most of the new proposals in this order's own Further Notice (para. 29).

The Commission framed the problem as over-breadth rather than under-enforcement:

"For example, if a consumer revokes consent in response to payment reminders under the current rule interpretation the caller must stop all future robocalls on unrelated matters such as fraud alerts, multi-factor authentication, appointment reminders, or utility outage calls even if that was not the consumer's will."

FCC 26-67, para. 11

The Two Revocation Tracks

The order splits revocation into two tracks, and which track applies depends on what kind of message prompted the opt-out. Coverage reporting a flat rollback of the revoke-all requirement is incomplete: the narrowing reaches informational messages only.

Informational calls: a revocation may be read narrowly

Amended 47 CFR 64.1200(a)(10) adds this sentence:

"Callers may interpret a revocation request made in response to an informational call or text message (i.e., a call or text message that does not contain any advertising or telemarketing) as applying only to the specific category of informational robocalls and text messages to which the revocation was directed and not to all communications."

FCC 26-67, Appendix A (amended 47 CFR 64.1200(a)(10))

Two words in that sentence do a lot of work. "May" means this is a permission the caller can take or leave, not a mandate, so a bank or utility that prefers to keep treating every opt-out as global may continue to do so. "Informational" is defined by footnote 31 of the order as a robocall that does not contain an advertisement or constitute telemarketing, by reference to the existing definitions at 47 CFR 64.1200(f)(1) and (f)(13).

The reasoning sits at paragraphs 10 through 12. Paragraph 10 states the modification "affects only informational robocalls." Paragraph 12 gives the Commission's reading of the statute:

"We conclude that the better reading of the TCPA permits consumers to avoid an all-or-nothing revocation by opting out of only those categories of informational robocalls they do not wish to receive while continuing to receive desired communications."

FCC 26-67, para. 12

The practical consequence runs both ways. A consumer who texts STOP to a payment reminder may keep getting that bank's fraud alerts and multi-factor authentication codes, which many people want. The same consumer may also have to opt out more than once to stop messages they do not want. Paragraph 26 acknowledges that trade-off and calls the added burden "minimal."

Advertising and telemarketing: revoke-all survives intact

Appendix A adds a second sentence that governs the other track:

"Revocation requests made in response to calls or text messages that contain an advertisement or constitute telemarketing revoke consent to all future calls or text messages containing an advertisement or constitute telemarketing from that caller."

FCC 26-67, Appendix A (amended 47 CFR 64.1200(a)(10))

Paragraph 14 explains why: advertising and telemarketing robocalls are "a specific category of communication for which there are no exemptions to the prior express consent requirement," so "consumers need only make a single revocation request to revoke consent to all future telemarketing robocalls from any caller." The same paragraph reminds telemarketers that under 47 CFR 64.1200(d)(5) a residential do-not-call request reaches affiliated entities where the consumer would reasonably expect it to.

One opt-out to a marketing text therefore still shuts off that caller's marketing. What changed is what happens when the message that prompted the opt-out was not marketing at all.

Callers Can Now Name One Exclusive Way to Opt Out

This reverses a bar the Commission has maintained in some form since 2015, when it ruled that a consumer may revoke in any reasonable manner "and that the consumer is not limited to using only a revocation method that the caller has established as one that it will accept" (quoted at para. 6 of the new order). The 2024 TCPA Consent Order, FCC 24-24, codified the point: its version of 64.1200(a)(10) ended with the sentence "Callers or senders of text messages covered by paragraphs (a)(1) through (3) and (c)(2) of this section may not designate an exclusive means to request revocation of consent." FCC 26-67 deletes that sentence and replaces it with a permission.

The three permitted methods

Paragraph 16 and amended (a)(10) allow a caller to designate as its exclusive revocation channel any one or more of exactly three mechanisms:

1. An automated, interactive voice or key-press activated opt-out mechanism on a call.
2. Replying to an incoming text with any one of seven standardized words: stop, quit, end, revoke, opt out, cancel, or unsubscribe.
3. A website or telephone number the caller designates to process opt-out requests.

Nothing else qualifies. These are the same three mechanisms the 2024 order had already blessed as reasonable per se; the change is that a caller may now make one of them the only channel it has to honor. As Appendix A puts it:

"Any caller that designates any of the methods identified above as the exclusive means to revoke consent is not required to process revocation requests made by any other means."

FCC 26-67, Appendix A (amended 47 CFR 64.1200(a)(10))

Footnote 42 confirms a caller may designate more than one of the three. Paragraph 18 declines a request to let callers designate a revocation method set by some other agency's regulations, reasoning that the record did not establish the consumer protections those alternatives afford.

The disclosure duty, and why all seven words still matter

Designation is conditional. The caller "must clearly and conspicuously disclose the designated method to revoke consent on the call or in the text," and paragraph 17 refuses to let callers decide for themselves when and how to give that disclosure.

Text senders got one accommodation. Because listing all seven words in every message would eat the character budget, a sender that designates reply text as its exclusive channel satisfies the disclosure by including at least one standardized word in each message, for instance by telling recipients to reply "stop." But the rule text conditions that accommodation on the sender recognizing any of the seven as valid. Paragraph 17 says so directly: text senders "still must honor revocation requests made using any of the standardized words."

That is the detail most likely to be missed. Advertising one word does not narrow the set a caller has to accept.

If a caller designates nothing, the old standard still governs

Amended 47 CFR 64.1200(a)(11) now opens: "Callers that do not designate an exclusive means to revoke consent pursuant to paragraph (a)(10) of this section must process revocation requests made by any reasonable means." It keeps both halves of the 2024 analysis: using a means not listed in (a)(10) "creates a rebuttable presumption that the consumer has revoked consent" once the called party produces evidence the request was made, and a totality of the circumstances analysis then decides whether the caller can show the request was not conveyed reasonably.

Paragraph 19 adds a limit worth noting. The change "does not alter the existing opt-out methods specified in our rules for calls made pursuant to an exemption or that include an advertisement or constitute telemarketing." Callers covered by 47 CFR 64.1200(b)(3) or 64.1200(a)(9) must still provide the opt-out mechanisms those provisions require.

What Did Not Change, and the Quiet Changes That Did

The ten business day processing window survives. Both amended (a)(10) and amended (a)(11) end with the same requirement: revocation requests "must be honored within a reasonable time not to exceed ten business days from receipt of such request." In (a)(11) that sentence is new. The 2024 rule put the deadline only in (a)(10), which applied it to requests "made in any reasonable manner"; the amended paragraphs split it, with (a)(10) now reaching requests "made in the manner described above" and (a)(11) carrying its own copy for callers that designate nothing. Nor did callers get extra runway: paragraph 24 declines one party's request to push the effective date out as much as 12 months after Federal Register publication. Paragraph 26 states flatly, "We impose no new compliance obligation."

The one-way texting allowance also survives. A sender using a protocol that cannot receive replies must still disclose clearly and conspicuously in each text that two-way texting is unavailable because of technical limitations, and must still provide reasonable alternative ways to revoke in each text.

Separately, the Commission delegated authority to the Consumer and Governmental Affairs Bureau, in consultation with the Enforcement Bureau, to recast the section 64.1200 robocall rules in plain language (para. 23). That delegation is deliberately bounded: "We make clear that substantive changes to these rules are excluded from this delegation of authority."

Two sets of changes the order does not discuss are visible in the rule text. Amended (a)(11) drops the 2024 rule's illustration of a non-designated channel, the words "such as a voicemail or email to any telephone number or email address intended to reach the caller," along with the word "other" in "any other means," and adds the processing deadline described above. The order's only word on that rewrite is footnote 43, which says the paragraph was amended accordingly and points to Appendix A. Amended (a)(12), the confirmation-text provision, drops the 2024 rule's "one-time" limitation, drops the condition that the confirmation be "the only additional message sent to the called party after receipt of the revocation request," and drops the mechanism that let a confirmation message ask a recipient to clarify which categories an opt-out covered. The five minute presumption stays: a confirmation sent within five minutes of receipt is presumed to fall within the consumer's prior express consent, and a slower one requires a showing that the delay was reasonable. Footnote 30 describes the (a)(12) edit only as conforming the text to the informational-category modification, and the Further Notice at paragraph 39 still seeks comment on confirmation and clarification messages.

The Fraud-Alert Exemption for Banks Gets Looser

Since 2015, financial institutions have had an exemption from the consent requirement for a narrow set of informational robocalls to wireless numbers: transactions suggesting a risk of fraud or identity theft, possible breaches of customer personal information, steps consumers can take to prevent or remedy breach harm, and actions needed to receive pending money transfers (47 CFR 64.1200(a)(9)(iii)(C)). One condition was that the institution call only a number the customer had provided to it directly.

That condition is now broader. Amended 47 CFR 64.1200(a)(9)(iii)(A) permits calls and texts to a wireless number "provided by the customer of the financial institution or obtained from a reliable source," and defines a reliable source as a number supplied by a spouse or other family member authorized to be on the account, obtained when the customer calls the institution, or included in records obtained from another financial institution.

The conditions the order left alone matter as much as the one it loosened. A financial institution may still send no more than three messages per event over a three-day period for an affected account under 64.1200(a)(9)(iii)(F), and must still honor opt-out requests immediately under (a)(9)(iii)(G) and (H). Paragraph 22 also encourages institutions to use the Reassigned Numbers Database at 47 CFR 64.1200(m) so alerts do not land on a number the customer no longer holds.

The Commission declined to go further. It found a request to extend the exemption to "other important customer communications" vague and beyond the limited scope of the 2025 Further Notice, and for similar reasons declined to address a request to extend the exemption beyond financial institutions (footnote 55).

The reach of the change is bounded by that definition. Those three routes are the whole of what amended (a)(9)(iii)(A) counts as a reliable source, and the family-member route reaches only a spouse or family member who is authorized to be on the account. A number from any other source still sits outside the exemption.

How This Fits the Standing TCPA Framework

The TCPA requires prior express consent for robocalls and robotexts to residential lines, wireless numbers and certain other specified numbers, absent an emergency purpose or an applicable exemption (47 U.S.C. 227(b)(1)(A), (B)). Everything in FCC 26-67 operates inside that structure; none of it changes when consent is required in the first place. Our guide to robocall, text and telemarketing law sets out the consent framework the order is amending.

The enforcement side is unchanged too, and it is the reason compliance staff read orders like this closely. Private suits run through 47 U.S.C. 227(b)(3) and 227(c)(5), which is why an opt-out that a caller fails to process is not merely a regulatory matter. We cover the statutory damages structure and how these cases proceed in our explainer on TCPA penalties and private lawsuits.

Debt collectors are one affected group: ACA International, a collection-industry trade group, joined the June 30, 2026 joint letter, and the order cites its comment on debt-collection revocation rules (fn 52). Our overview of federal debt collection rules covers the separate notice and communication limits. Banks, utilities and health care providers are the other commenters the order names (paras. 5 and 26).

The courts are also actively drawing lines around which TCPA provisions reach texts at all. We reported on the Seventh Circuit's holding that the private right of action in 227(c)(5) does not cover text messages in this analysis of the Seventh Circuit's text-message ruling. Read together with FCC 26-67, the field a caller has to track is now split by message type in two different directions at once: by advertising content under the FCC's rule, and by medium under that court's reading of the statute.

What the FCC Is Still Asking About

Everything in this section is a proposal in the Further Notice of Proposed Rulemaking. None of it is law, and the Commission has not committed to adopting any of it.

A shorter deadline to honor opt-outs. Paragraphs 30 and 31 ask whether the ten business day maximum should come down, noting that the June 30, 2026 joint letter suggested seven business days unless the caller shows a longer period is reasonable. The Commission also asks whether the deadline should differ between callers that designate an exclusive method and callers that do not, and whether varying deadlines would confuse consumers.

Ending one-way texting. Paragraphs 32 through 34 ask whether to delete the provision allowing a sender to use a protocol that cannot receive reply texts, which would make reply-text revocation always available. The Commission asks how widely one-way protocols are actually used and whether to allow them for informational messages while requiring two-way texting for advertising.

A mandatory one-step revoke-all. Paragraph 13 and paragraphs 35 and 36 ask whether a caller should be allowed to read a revocation narrowly only if it also offers a method to revoke consent for all message types requiring consent, and whether such a mechanism must be automated. Paragraph 35 also asks about Edison Electric Institute's request that a revocation apply only to the telephone number for which consent was revoked rather than to every number associated with a customer's account.

Affiliates and lines of business. Paragraphs 37 and 38 ask whether to give more specific guidance where a company operates through separate affiliates, divisions or lines of business, and whether the existing affiliate standard in 64.1200(d)(5) should be extended beyond exempted and telemarketing calls to all robocalls. Footnote 84 reproduces the proposed new paragraph (a)(13) the joint filers suggested.

Several smaller items. Paragraph 39 collects the rest: shortening the list of standardized revocation words, eliminating the rebuttable presumption analysis in (a)(11), and allowing confirmation calls or texts, including Vibes Media's request that a sender be allowed to ask which category of message a consumer meant to stop.

Comments are due 30 days after Federal Register publication and replies 60 days after publication, both filed in CG Docket No. 02-278 through the Commission's Electronic Comment Filing System. Because publication has not happened, those dates do not exist yet either.

When This Takes Effect, and Why No Date Exists Yet

This timeline carries five separate dates, and they are easy to conflate.

Adopted: September 30, 2026. Released: October 1, 2026. Adoption is when the Commission acted on the item; release is when the text became public. Neither makes a rule effective.

Federal Register publication: has not happened. We checked the Federal Register's own database on October 8, 2026, both its published documents and its public inspection list of documents awaiting publication. FCC 26-67 appears in neither.

Effective date: not yet fixed. The ordering clause at paragraph 50 sets the effective date of the amendments at 30 days after Federal Register publication. Footnote 64 states that the Commission "will release a Public Notice indicating the specific effective date when that information becomes available." Until publication occurs, there is no date to name, and anyone citing one is guessing.

Comment and reply dates: also not yet fixed, for the same reason.

January 31, 2027, the date that is about to stop mattering. The revoke-all requirement from the 2024 order never actually took effect. A Federal Register notice published October 11, 2024 at 89 FR 82518 set an April 11, 2025 effective date for the 2024 TCPA Consent Order's amendments. The Consumer and Governmental Affairs Bureau then waived just the revoke-all piece, first to April 11, 2026, then to January 31, 2027 in DA 26-12, adopted and released January 6, 2026. Paragraph 24 of the new order addresses that directly: the amendment to (a)(10) "will go into effect at that time and supersede the delayed effective date of the relevant portion of that rule that was previously extended to January 31, 2027."

The order does not say what happens if Federal Register publication occurs after January 31, 2027. We do not address that scenario.

One procedural note on timing: paragraph 44 records that the Commission determined, with the concurrence of the Administrator of the Office of Information and Regulatory Affairs, that the rule is "non-major" under the Congressional Review Act, 5 U.S.C. 804(2). A copy goes to Congress and the Government Accountability Office under 5 U.S.C. 801(a)(1)(A).

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

The useful way to read FCC 26-67 is as a trade of one kind of certainty for another. The 2024 rule gave consumers a blunt instrument: one opt-out, any wording a reasonable person would read as an opt-out, any channel, everything stops. It was simple to invoke and genuinely hard to administer, and the record the Commission assembled is unusual in that consumer groups and industry largely agreed about the problem. Paragraph 5 notes that no commenter opposed modifying the revoke-all requirement, though some conditioned their support on callers offering a way to revoke consent to all messages requiring it. Paragraph 12 adds a qualifier the record summary leaves out: one party did oppose the change, in a September 15, 2026 ex parte filing arguing that the revisions make compliance more complex, and the Commission concluded that the support outweighed it.

What replaces it is more precise and more fragmented. A consumer's opt-out now means different things depending on whether the message that prompted it was selling something, and the channel that counts may be one the caller picked. The compliance burden drops; the burden of knowing how to be left alone rises.

The exclusive-method provision is where that shift is sharpest, and it is worth being clear about what the Commission did and did not do. It did not let callers invent opt-out channels. The list is three items long, every one of them automated or trivially reachable, and paragraph 15 says the point is to prevent "unduly complex, difficult, or cumbersome methods that could prevent or deter consumers from revoking consent effectively." The disclosure duty and the requirement to honor all seven standardized words are the real guardrails, and both are drafted as conditions rather than best practices.

The structural asymmetry is deliberate and, in our reading, the order's most defensible choice. Telemarketing keeps revoke-all because, as paragraph 14 reasons, there is no exemption from consent for advertising calls, so a single category can carry a single switch. Informational messages are a genuinely mixed bag, where a fraud alert and a payment reminder from the same bank can have opposite value to the same person. Treating those two sets alike was the flaw the record kept returning to.

The claim in paragraph 26 that the order imposes "no new compliance obligation" is accurate as far as it goes, since nothing here is mandatory. It understates the practical reality. Any caller that chooses to take the new flexibility has to build category tracking, write a disclosure into every call script and message template, and keep honoring seven keywords it may only be advertising one of. Callers that change nothing are untouched. The quiet edits to (a)(12), stripping the one-time and only-message conditions from the confirmation-text safe harbor while the Further Notice still asks about confirmation messages, are worth flagging precisely because the order's discussion does not explain them.

One consequence of the fraud-alert change is worth naming as our own reading, since the order does not discuss it. A bank may now place an exempted alert on a number the customer never handed over, so a genuine alert can arrive on a number the recipient does not associate with that bank, which is harder to tell apart from a message impersonating a bank's security team. Our coverage of how government and institutional impersonation scams actually work describes that overlap in detail.

One date governs everything downstream: Federal Register publication. It starts the 30 day clock to effectiveness, sets both comment deadlines, and resolves the awkward relationship between these amendments and the January 31, 2027 waiver.

Who This Reaches First

The exclusive-method and category provisions are options a caller has to affirmatively elect and disclose, so the immediate audience is compliance staff at banks, credit unions, utilities, healthcare providers, collection agencies and retailers. A caller that elects nothing is governed by the same reasonable-means standard it already follows.

For TCPA matters, once the amendments take effect, the amended (a)(10) text makes one characterization relevant to the scope of an opt-out: whether the message that prompted the revocation contained an advertisement or constituted telemarketing within 47 CFR 64.1200(f)(1) and (f)(13). Before this order, that characterization bore on which exemption and which opt-out mechanism applied.

This is general legal information, not legal advice. It covers federal law in the United States and reflects sources verified on October 8, 2026. Laws change and this story is developing; consult a lawyer licensed in your jurisdiction about your specific situation.

Related articles

• TCPA Explained: Robocall, Text, and Telemarketing Law
• TCPA penalties and private lawsuits
• Federal debt collection rules
• Seventh Circuit: the 227(c)(5) do-not-call action does not cover texts
• Government impersonation scams

Last updated: 2026-10-08. This is a developing story; details verified as of 2026-10-08.

Frequently Asked Questions

Is the new FCC TCPA consent revocation rule in effect now?

No. The FCC adopted FCC 26-67 on September 30, 2026 and released it on October 1, 2026, but the amendments take effect 30 days after publication in the Federal Register. As of October 8, 2026 the order had not been published and was not on the Federal Register's public inspection list, so no effective date exists yet. Footnote 64 of the order says the Commission will announce the specific date by Public Notice.

Does replying STOP to a marketing text still stop all marketing from that company?

Yes. Amended 47 CFR 64.1200(a)(10) states that revocation requests made in response to calls or texts containing an advertisement or constituting telemarketing revoke consent to all future advertising and telemarketing calls or texts from that caller. Paragraph 14 of the order explains that consumers need only make a single revocation request to stop all future telemarketing robocalls from a caller. The narrowing in this order applies only to informational messages.

What counts as an informational call under the new rule?

Footnote 31 of FCC 26-67 defines an informational robocall as one that does not contain an advertisement or constitute telemarketing, using the existing definitions at 47 CFR 64.1200(f)(1) and (f)(13). Appointment reminders, fraud alerts, multi-factor authentication codes, payment reminders and utility outage notices are the examples the order uses at paragraph 11.

Can a company now force consumers to use only one opt-out method?

A caller may designate an exclusive method, but only from three options in amended 47 CFR 64.1200(a)(10): an automated interactive voice or key-press opt-out on the call, a reply text using one of seven standardized words, or a website or telephone number the caller designates. The caller must clearly and conspicuously disclose the designated method on the call or in the text. A caller that designates none of them must still process revocation made by any reasonable means under amended (a)(11).

Which seven words work in a reply text?

Stop, quit, end, revoke, opt out, cancel and unsubscribe. Amended 47 CFR 64.1200(a)(10)(ii) lists them, and paragraph 17 of the order confirms that a text sender which advertises just one of them in its messages must still honor revocation requests made using any of the seven.

How long does a caller have to honor a revocation request?

A reasonable time not to exceed ten business days from receipt. Both amended (a)(10) and amended (a)(11) retain that language and FCC 26-67 did not shorten it. The Further Notice at paragraphs 30 and 31 asks whether to reduce the maximum, and notes a June 30, 2026 joint letter from the American Bankers Association, the National Consumer Law Center and ACA International suggesting seven business days, but that is a proposal and not a rule.

What happened to the January 31, 2027 revoke-all deadline?

It is superseded once these amendments take effect. The revoke-all portion of the 2024 rule was waived by the Consumer and Governmental Affairs Bureau, first to April 11, 2026 and then to January 31, 2027 in DA 26-12, adopted January 6, 2026. Paragraph 24 of FCC 26-67 states that the amendment to section 64.1200(a)(10) will go into effect 30 days after Federal Register publication and supersede that delayed effective date. The order does not address what happens if publication slips past January 2027.

What changed for bank fraud alerts?

Amended 47 CFR 64.1200(a)(9)(iii)(A) lets a financial institution send exempted fraud-alert calls and texts to a wireless number provided by the customer or obtained from a reliable source, defined as a number supplied by a spouse or other authorized family member on the account, obtained when the customer calls the institution, or included in records obtained from another financial institution. The other conditions on that exemption stand, including the limit of three messages per event over a three-day period in (a)(9)(iii)(F) and the duty to honor opt-outs immediately.

Does this order affect the right to sue over robocalls?

FCC 26-67 does not amend the TCPA's private rights of action at 47 U.S.C. 227(b)(3) or 227(c)(5). It changes the scope of what a revocation covers and the channels a caller must honor, which bears on whether a given call was made without consent, but the statutory damages structure is untouched.

Where can the public comment on the proposals?

In CG Docket No. 02-278, through the Commission's Electronic Comment Filing System. Comments are due 30 days after Federal Register publication and reply comments 60 days after publication. Because the order has not been published, neither deadline has a calendar date yet.