FCC One-to-One Consent Rule for TCPA: What It Means for Your Business

This guide will walk you through what the FCC One-to-One Consent Rule was, why TCPA compliance still matters today, and what steps you must take to protect your business.

What is the FCC One-to-One Consent Rule?

The FCC one-to-one consent rule required businesses to obtain prior express written consent from consumers, explicitly authorizing individually named businesses to contact them using automated systems (calls or texts).

Key points:

• Consent had to be separate and specific for each business.
• It targeted bulk lead sharing without individual consumer approval.
• It aimed to curb unwanted or fraudulent communications inundating consumers.
• Compliance was originally required by January 27, 2025.

Although a court decision halted enforcement, businesses must still follow strict TCPA consent form rules for outreach compliance.

Why Was This Rule Introduced?

The FCC introduced the rule to:

• Protect consumers from receiving marketing from companies they never knowingly engaged with.
• Stop abusive lead generation practices, where a single opt-in could result in calls or texts from dozens of unknown businesses.
• Enhance transparency by requiring businesses to name themselves clearly at the point of consent.
• Raise lead quality by ensuring contacts are genuinely interested.

What Happened to the FCC One-to-One Consent Rule?

In early January 2025:

• The effective date was paused following a directive from the White House to freeze new regulatory changes.
• Shortly after, the Eleventh Circuit Court of Appeals ruled in favor of the Insurance Marketing Coalition, challenging the FCC’s authority to mandate the one-to-one consent update.
• As a result, the one-to-one consent rule was eliminated before it went into effect.

However, the core TCPA requirements for obtaining prior express written consent remain unchanged and enforceable.

Why TCPA Consent Still Matters

Even though the one-to-one update was repealed, businesses must still adhere to the TCPA’s original consent standards. Respecting consumer preferences today is essential for:

• Reducing legal risk like TCPA violations that carry severe fines.
• Improving customer trust by demonstrating respect for privacy.
• Building stronger, long-term customer relationships.

Proper consent gathering reflects integrity and protects your brand from regulatory and reputational harm. 

Key TCPA Compliance Requirements

To stay compliant, businesses must follow these existing TCPA obligations:

• Obtain Prior Express Written Consent: Businesses must obtain and retain consumer consent - captured via signature, digitally or physically - before using automated technology (calls or texts) for marketing. Read about TCPA compliance best practices for text messages here: TCPA Compliance for SMS Marketing in the US
• Clear and Conspicuous Disclosure: Consent language must clearly inform consumers they are agreeing to receive robocalls or robotexts from a specifically identified business.
• Respect Do-Not-Call Regulations: Marketing communications must not be sent to numbers on the National Do-Not-Call Registry without prior express permission.
• Maintain Consent Records: Advertisers, lead generators, and lead buyers must securely retain consent documentation for at least five years, in case of audits or lawsuits.
• Revocation of Consent: Starting April 11, 2025, consumers can revoke consent at any time by any reasonable means. Businesses must process revocation requests within 10 business days. A one-time confirmation message may be sent for clarification.

How the Rule Impacts Your Business

If your business handles lead generation, telemarketing, or SMS marketing, the TCPA affects you directly.

You must:

• Carefully document each consent event.
• Use transparent opt-in forms.
• Adjust lead purchase agreements to verify consent quality.
• Train teams on TCPA compliance, especially regarding opt-outs and DNC handling.

Ignoring these rules can lead to:

• Financial penalties of $500–$1,500 per violation.
• Class action lawsuits from consumers.
• Operational disruptions caused by court-ordered injunctions.
• Reputational damage that erodes brand trust over time.

5 Steps to Ensure TCPA Compliance

Here’s how businesses can future-proof their lead generation and outreach practices:

1. Audit Consent Processes: Check where and how consent is collected and whether documentation meets TCPA standards.
2. Revise Opt-In Forms and Scripts: Ensure that every consumer knows who will contact them and via what channels. Explore Lead Generation Form Examples here.
3. Train Staff and Partners: Regularly educate employees and third-party vendors on compliant practices.
4. Document and Retain Consent: Keep detailed, time-stamped records of every consumer consent you collect. You should be able to prove who consented, when they consented, and what exact language they agreed to. Form builder platforms like MakeForms make this easier by allowing you to build compliant lead generation forms with embedded consent capture, customizable disclosures, and exportable audit trails.
5. Enable Easy Opt-Outs: Always offer a clear, accessible method for consumers to withdraw consent.

Best Practices for TCPA Compliance

• Use Clear Language: No confusing legalese, just simple and direct consent forms.
• Obtain and Retain Digital Records: Store consent details like timestamp, consent language, and identity verification.
• Make Opting Out Easy: Always include easy unsubscribe options in calls and texts.
• Regularly Review Compliance Policies: Update your practices to align with the latest interpretations of the TCPA and related case law.

Why MakeForms Helps with TCPA Compliance

MakeForms is an essential tool for businesses aiming to stay TCPA-compliant without complicating their operations.

Here’s how it helps:

• Customizable Consent Fields: Add clear, conspicuous consent checkboxes and disclosures at form entry points.
• Audit-Ready Records: Capture detailed, timestamped evidence of each user’s consent, ready for internal audits or external legal defense.
• Easy Data Export: Quickly generate and export consent logs, making it simple to respond to regulatory inquiries or lawsuits.
• Lead Verification Support: Ensure that only leads with valid prior express written consent are routed to your sales or marketing teams.

By using a solution like MakeForms, businesses can confidently meet all TCPA compliance requirements while streamlining their lead capture processes.

Why Consent-First Lead Generation Still Matters (With or Without the One-to-One Rule)

Whether the one-to-one consent rule stayed or not, the message from the FCC and courts is clear: Consumer consent must be explicit, traceable, and respected.

Businesses that prioritize compliant lead generation and responsible communication not only stay out of legal trouble but also build lasting, trust-driven customer relationships.

Stay updated with the latest TCPA developments, and ensure your lead generation forms, lead generation form examples, and processes align with best practices.For more detailed compliance steps required in a lead gen form with examples, see our TCPA Compliance Checklist.