FCC adopts the 'one-to-one' consent rule

The FCC adopted a rule requiring prior express written consent to be given to one seller at a time, tied to a logically and topically related interaction. It was set to take effect January 27, 2025, and would have ended multi-buyer comparison-site consent as commonly used in lead gen.

General information, not legal advice. Confirm anything you act on with TCPA counsel.

What changed

In December 2023 the FCC adopted a rule that would have required prior express written consent to be given to a single seller at a time, tied to a logically and topically related interaction. It was set to take effect January 27, 2025.

The rule would have ended common comparison-site consent covering many 'marketing partners'. It was vacated by the 11th Circuit before it took effect.

What it means for pay-per-call teams

Lead forms listing many 'marketing partners' would no longer have counted as consent for each partner.

Checklist

• Historical context only; see the 2025 entries for the current status