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 24 January 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 11 April 2025, the window to honour an opt-out is 10 business days, down from 30. This one is real and it is the change most likely to catch an operations team out.
- The "revoke-all" provision: still suspended. It has been waived twice and the FCC has proposed deleting it outright.
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.
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 for eighteen months, 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.