One-to-one consent: what it means in pay per call
One-to-one consent: A 2023 FCC rule that would have required prior express written consent to be given to one seller at a time. The 11th Circuit vacated it in January 2025.
How it works in pay per call
The FCC adopted the one-to-one consent rule in December 2023. It would have ended the common lead-gen practice of one consent covering a long list of 'marketing partners'. It was set to take effect on January 27, 2025.
On January 24, 2025, the 11th Circuit (Insurance Marketing Coalition v. FCC) held that the FCC exceeded its authority and vacated the rule. The FCC postponed the effective date that same day. In August 2025 a Federal Register notice restored the earlier text of 47 CFR 64.1200(f)(9).
Multi-seller consent is still possible, but the disclosure must be clear, and each seller must be properly identified. Separate rules still apply: CMS's TPMO data-sharing consent rule for Medicare survived its own court challenge.
Example
Example: under the vacated rule, a comparison site listing 50 insurance 'partners' under one checkbox would not have given valid consent to each partner. Today, multi-seller consent can still work if the disclosure is clear and each seller is properly identified.
Frequently asked questions
What is One-to-one consent?
A 2023 FCC rule that would have required prior express written consent to be given to one seller at a time. The 11th Circuit vacated it in January 2025.
Can you give an example of One-to-one consent?
Example: under the vacated rule, a comparison site listing 50 insurance 'partners' under one checkbox would not have given valid consent to each partner. Today, multi-seller consent can still work if the disclosure is clear and each seller is properly identified.