FCC formally removes the vacated one-to-one language

A Federal Register notice reinstated the prior text of 47 CFR 64.1200(f)(9), closing out the one-to-one rule after the 11th Circuit's mandate issued April 30, 2025.

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

What changed

After the 11th Circuit vacated the one-to-one consent rule and its mandate issued on April 30, 2025, the FCC published a Federal Register notice on August 29, 2025. It reinstated the earlier text of 47 CFR 64.1200(f)(9), the definition of prior express written consent.

This formally ends the one-to-one rule in the CFR. The consent definition reads as it did before the 2023 order.

What it means for pay-per-call teams

The consent definition in the CFR is back to its pre-2023 wording.

Checklist

• Confirm your consent language meets the restored 64.1200(f)(9) definition
• Keep seller names clearly disclosed on multi-seller forms