FCC Issues Final Rule Formally Eliminating the One-to-One Consent Requirement
Source: Consumer Finance Insights, Goodwin Procter LLP — Richard Sillett
Published: September 15, 2025
Key Facts
Background — the vacated rule: The FCC's 2023 one-to-one consent rule (47 CFR § 64.1200(f)) required that prior written consent for robocalls be limited to a single designated seller; lead-generation aggregation of consent was prohibited.
Court action: The U.S. Court of Appeals for the Eleventh Circuit vacated the rule in Insurance Marketing Coalition Limited v. FCC (127 F.4th 303, 2025). The court held the FCC exceeded statutory authority, finding "prior written consent" requires only clear and unmistakable disclosure that calls may come from multiple sellers.
FCC Final Rule (September 2025): The FCC issued a Final Rule formally eliminating the one-to-one consent requirement, conforming agency rules to the Eleventh Circuit decision. Effective date: September 2025.
What remains in effect: Standard TCPA prior express written consent (PEWC) requirements for automated marketing calls and texts continue to apply. Multi-seller consent bundles are now permissible provided the consent disclosure is clear and unmistakable about multiple senders.
Relevance to KG
- Supplements [[source.fcc-gov.document-fcc-removes-one-one-consent-rule-nullified-court-decision-2025]] with law-firm legal interpretation.
- Relevant to [[constraint.tcpa-prior-express-written-consent-sms]] — body should note that the one-to-one restriction was vacated and formally eliminated in 2025; standard PEWC remains.
- Related to [[source.wiley-law.alert-update-11th-circuit-vacates-fccs-one-to-one-tcpa-consent-rule-2025]] (earlier alert covering the vacatur itself).