What happened to the FCC's one-to-one consent rule? A timeline

Is the one-to-one consent rule still in effect?

No. The rule required a consumer's prior express written consent to name a single identified seller and to cover only calls or texts 'logically and topically' tied to the interaction that produced it. It was due to take effect January 27, 2025. Three days before that, on January 24, 2025, the FCC postponed the effective date, and the Eleventh Circuit Court of Appeals vacated the rule outright the same day. It was formally written out of the Commission's regulations on July 14, 2025, effective August 29, 2025. At no point did a business ever have to comply with it.

Where the rule came from: the 'lead generator loophole'

The FCC adopted the rule in its Second Report and Order under the Telephone Consumer Protection Act, published in the Federal Register on January 26, 2024. The target was comparison-shopping and lead-generation sites where one consent checkbox could authorize calls or texts from dozens of unrelated companies the consumer never saw named. The new rule would have required that consent name exactly one seller and that any resulting message be logically and topically related to what the consumer was doing when they consented.

The Insurance Marketing Coalition, a trade group representing insurance lead generators and marketers, petitioned the Eleventh Circuit for review of the rule on the same day it was published, arguing the FCC had rewritten what 'consent' means under the statute rather than implementing it.

Timeline: postponed and vacated on the same day

1. 1

   Jan 26, 2024 — rule published, challenge filed

   The FCC's revised 47 CFR 64.1200(f)(9) is published in the Federal Register with an effective date of January 27, 2025. The Insurance Marketing Coalition (IMC) petitions the Eleventh Circuit for review the same day.

2. 2

   Dec 18, 2024 — oral argument

   The Eleventh Circuit hears oral argument in Insurance Marketing Coalition Ltd. v. FCC, a little over five weeks before the rule's planned start date.

3. 3

   Jan 24, 2025 — the FCC postpones the rule...

   Three days before the effective date, the FCC's Consumer and Governmental Affairs Bureau postpones the start date by up to 12 months, to January 26, 2026, citing the pending appeal and the burden of complying with a rule that might not survive review.

4. 4

   ...and the court vacates it, same day

   Hours later, a unanimous Eleventh Circuit panel grants IMC's petition and vacates the one-to-one and 'logically and topically related' requirements, holding the FCC exceeded its authority under the TCPA by narrowing the ordinary legal meaning of 'prior express consent.'

5. 5

   Apr 30, 2025 — the court's mandate issues

   The Eleventh Circuit's mandate, the order that makes a vacatur legally effective, issues on April 30, 2025.

6. 6

   Jul 14, 2025 — the FCC deletes the vacated text

   The Commission's Bureau issues a ministerial order repealing the revised language and reinstating the version of 47 CFR 64.1200(f)(9) that existed before the 2023 order, finding it had no discretion to depart from the court's mandate. The change takes effect on publication in the Federal Register, August 29, 2025.

What the rule would have required, and why the court said no

Beyond naming one seller, the rule would have barred using a single consent for messages outside the topic that produced it — a consumer who agreed to hear from auto lenders while shopping for a car loan could not lawfully be contacted about an unrelated credit-repair offer, even with the same signed form on file. The FCC's stated aim was to stop a purchased or shared lead from fanning out into calls and texts from sellers the consumer never agreed to hear from.

The Eleventh Circuit did not dispute that goal, but found the FCC had no authority to redefine 'prior express consent' to require it. The TCPA (47 U.S.C. 227) does not define the phrase, so the court applied its ordinary, common-law meaning: a person consents by clearly and unmistakably stating they are willing to receive the call, a standard that does not require naming a single company or limiting the subject matter. The FCC's own brief had conceded that a consumer could, as a factual matter, knowingly consent to calls from several named companies at once — which the vacated rule categorically forbade regardless.

What applies now, and what's gone

The 10-business-day revocation deadline and the Do Not Call Registry rules come from separate FCC proceedings; neither was before the Eleventh Circuit in this case.

What this means if your business buys, shares or calls on leads

• A shared or co-registration consent covering several named sellers is legal again — it was never illegal for the roughly 13 months between the rule's adoption and its vacatur, because it never took effect.
• The bar that never moved still applies: get a signed, written agreement before any autodialed or prerecorded marketing call or text, disclosing that it's coming and naming the phone number.
• Review any consent language or vendor contract written in 2024 to over-comply with the one-to-one rule in anticipation of its start date; that restriction is no longer a legal requirement, though a platform or carrier may still contractually require it.
• Keep honoring a revocation of consent however it's expressed, within 10 business days — that rule is separate and still in force.
• Treat this as settled for now, not permanent: the FCC could open a fresh rulemaking addressed to the court's specific objections, this time through full notice and comment.

Could the one-to-one rule come back?

The Eleventh Circuit's ruling stops the FCC from redefining 'prior express consent' to require a single named seller through the authority it claimed in 2023; it does not stop Congress from writing that requirement into the TCPA itself, or the FCC from trying a narrower version grounded in different statutory authority. Neither has happened as of this writing. Businesses that route calls or texts through a platform, Lead Friendly included, should treat the written-consent standard in 47 CFR 64.1200(f)(9) as the current baseline and watch for any new FCC proceeding rather than assume today's rule is final.

This section describes the law as of this post's publish date and is not legal advice. Verify current status on fcc.gov or with counsel before relying on it.