Analysis
The One-to-One Consent Rule Never Took Effect. Guides Still Say It Did.
Is the FCC one-to-one consent rule in effect?
Short answerNo. The FCC's one-to-one consent rule was vacated by the Eleventh Circuit on January 24, 2025 in Insurance Marketing Coalition Ltd. v. FCC and never took effect. A single consent form naming multiple sellers can still be valid. The pre-existing prior express written consent requirements continue to apply unchanged.
Checking a whole list? Preview 20 rows of it free →
About NumberBroom. NumberBroom scrubs phone lists before you dial: it removes known litigators, returns each number it keeps with its line type and carrier, and gives every job a dated record of the screening. $0.20 a number, less past 2,000 rows, no subscription.
Where a scrub fits: A scrub does not check consent, so it cannot fix a lead collected without it. It removes known litigators, who seed their numbers into lead forms so the consent record on file is worthless, before anyone dials them.
On this page
In December 2023 the FCC adopted a rule that would have required telemarketing consent to be given to one seller at a time, and limited resulting calls to subjects "logically and topically associated" with the interaction that produced the consent. It was aimed squarely at lead generation, where a single form routinely authorises dozens of buyers at once.
It never took effect. On January 24, 2025, the Eleventh Circuit vacated it in Insurance Marketing Coalition Ltd. v. FCC, No. 24-10277, holding that the Commission had exceeded its statutory authority because the rule conflicted with the ordinary meaning of "prior express consent." The court remanded to the agency, which has no deadline to act and has not acted.
Why the error is still everywhere
A large volume of compliance content was written in 2024, while the rule was adopted but not yet in force. That content was accurate when published. It described an upcoming requirement, offered checklists for preparing, and in a number of cases was attached to a product that would help you comply.
Then the rule was vacated, and very little of that content was revisited. Search results for one-to-one consent still surface pages that describe compliance deadlines which no longer exist, because nobody has a strong incentive to go back and unpublish a page that generates leads.
How to date a page you are reading
If a guide describes one-to-one consent as upcoming, pending, or effective from a date in 2024 or 2025, it has not been updated since January 2025. Treat everything else on that page as equally stale -- including any figure it quotes for statutory damages or scrubbing intervals.
What actually changed, and what did not
It is worth separating the three things that get conflated:
- One-to-one consent: vacated. Never in force. The pre-existing prior express written consent standard governs.
- The revocation rules: in force. Effective April 11, 2025, the window to honour an opt-out is 10 business days, and company-specific do-not-call requests, which used to get 30 days, get the same 10 business days. This one is real and it is the change most likely to catch an operations team out.
- The "revoke-all" provision: still suspended. It is waived until January 31, 2027. On September 30, 2026, the FCC adopted an order (FCC 26-67) that narrows it so an opt-out covers only the category of informational message it answered, replacing the waiver 30 days after the order is published in the Federal Register, which had not happened as of October 8, 2026. See the FCC's TCPA opt-out order.
Two of those three are frequently reported backwards. The vacated rule gets described as live; the live revocation deadline gets described as 30 days.
What this means if you buy leads
Relief from a rule that never existed is not the same as safety. The vacated rule would have tightened a standard that was already binding, and the pre-existing standard is not permissive: consent has to be a signed written agreement, naming the seller, authorising that number, disclosing that consent is not a condition of purchase, and retained in a form you can produce later.
The part that has not moved at all is who bears the risk. If a lead vendor's consent record turns out to be inadequate, the call was still yours. Buying leads transfers the work of collecting consent; it does not transfer liability for calling without it.
And none of this touches the population that actually sues. Serial TCPA litigators seed their numbers into lead forms deliberately, which means the consent record on file may be technically genuine and completely worthless -- it documents that someone submitted the number, which is exactly what the plaintiff intended.
Quick check: which consent rules are live
Pick an answer to see whether it is right, and why.
The short version
Nothing about the vacatur requires you to change a process today. What it should change is how much you trust the compliance content you are reading: a page that still describes one-to-one consent as coming has been wrong since January 2025, and it is probably wrong about the opt-out window too.
For the current position across all of it, see the TCPA compliance guide, which carries a dated accuracy note and is corrected in place.
Frequently asked questions
So can one lead form still name multiple buyers?
Yes, on the federal position as it currently stands. The rule that would have restricted this was vacated before it took effect, so the pre-existing standard governs: consent must be a signed written agreement clearly authorising the specific seller to contact that specific number using an autodialer or prerecorded voice.
"Clearly authorising the specific seller" is doing real work in that sentence. A form listing sixty partner names behind a scroll box was arguably non-compliant long before the vacated rule existed, and it still is.
Could the rule come back?
Possibly. The Eleventh Circuit remanded to the FCC, and the agency is under no deadline to act. It could attempt a revised rule on firmer statutory footing, or leave it. Nothing is currently pending that changes the operating position.
The practical read: do not build a process that depends on the rule staying dead, and do not build one that assumes it is live.
What did the court actually hold?
That the FCC exceeded its statutory authority. The rule conflicted with the ordinary meaning of "prior express consent" as used in the statute -- Congress set that standard, and the court held the agency could not narrow it by regulation into something more demanding.
That reasoning matters beyond this rule, because it constrains how far the FCC can move consent requirements without Congress.
- 47 U.S.C. § 227 -- Restrictions on the use of telephone equipment (Cornell LII)
- FCC -- Telephone Consumer Protection Act rulemaking
- FCC -- CGB extends the effective date of the TCPA's consent revocation rule (DA 26-12, January 6, 2026)
- FCC -- Report and Order and FNPRM on consent revocation, adopted September 30, 2026 (FCC 26-67)