FCC One-to-One Consent Rule
A 2024 FCC rule that requires TCPA consent to name a single seller, closing the "lead generator loophole" that allowed bundled consent across hundreds of partners.
Full Definition
In December 2023, the FCC adopted a rule amending TCPA consent requirements so that "prior express written consent" must authorize calls from only one seller at a time and must be "logically and topically associated" with the interaction that prompted the consent. The rule was originally slated to take effect January 27, 2025, but on January 24, 2025 the Eleventh Circuit Court of Appeals (in IMC v. FCC) vacated the one-to-one requirement, holding that the FCC exceeded its statutory authority. As a result, the one-to-one rule is not currently enforceable at the federal level, though many lead buyers and sellers voluntarily adopted one-to-one consent flows and continue to use them. State attorneys general and private TCPA plaintiffs still pursue the underlying "bundled consent" theory aggressively.
Example
A lead form that previously read "I consent to be contacted by InsureLeads and its marketing partners" was updated in late 2024 to present the consumer with a checkbox per seller — forcing the consumer to affirmatively select each company. Many lead vendors have kept this flow post-IMC to reduce litigation risk.
Common Misconceptions
The one-to-one rule is often described as "currently in effect." It is not — the Eleventh Circuit vacated it in January 2025. However, one-to-one consent remains a best practice and is required by many carriers and lead networks via contract.
Related Terms
- TCPA (Telephone Consumer Protection Act) — U.S. federal law restricting telemarketing calls, autodialed calls, prerecorded messages, and text messages without prior express written consent.
- Prior Express Written Consent (PEWC) — A TCPA-defined standard of consent requiring a signed, written agreement that clearly authorizes autodialed or prerecorded marketing calls and texts.
- TrustedForm — A consent-capture product from ActiveProspect that records a video-like replay of a consumer's interaction with a lead form as evidence of TCPA consent.
- Jornaya LeadID — A competing consent-capture product (now part of Verisk) that generates a unique LeadID token documenting the consumer's interaction with a lead form.