FCC Removes One-to-One Consent Rule Nullified by Court Decision (2025)

Official FCC document record for the removal of the one-to-one TCPA prior express written consent rule.

Key facts surfaced (2026-05-07, via search and legal alert cross-referencing):

• Court vacatur: On January 24, 2025, the U.S. Court of Appeals for the Eleventh Circuit vacated the FCC's one-to-one consent rule in Insurance Marketing Coalition v. FCC, finding the rule exceeded the FCC's statutory authority under the TCPA.
• FCC response: The FCC issued a stay of the rule immediately after the vacatur, then formally removed the rule and reinstated the prior standard.
• Reinstatement date: August 29, 2025 — FCC reinstated the prior "prior express written consent" (PEWC) standard, deleting the vacated one-to-one rule language from its rules (47 CFR § 64.1200(f)(9)).
• Multi-seller consent: Multi-seller consent (a single consumer consent covering multiple sellers) is now legally permissible again under federal law.
• PEWC still required: Prior express written consent for marketing SMS/robocalls remains a binding TCPA requirement. Only the one-to-one restriction was removed.
• State law: State-level SMS consent laws remain in effect and may impose stricter requirements than the reinstated federal standard.

Impact on existing KG nodes:

• concept.consent-management body contains an outdated reference to "the FCC one-to-one rule" being in effect as of January 2026. This is materially incorrect — the rule was vacated before it ever took effect. Body correction drafted in evolution-log/2026-05-07/web-refresh.md.
• source.activeprospect-com.blog-tcpa-text-messages-2026 body states the one-to-one rule is effective — this source now requires a correction note.