One-to-One, the Repeal & TCPA Litigation

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For a while the entire lead-gen industry braced for the FCC’s "one-to-one consent" rule, which was written specifically to break the practice of sharing a single consumer’s consent across a long list of partners. Then it was vacated by a federal appeals court and formally repealed. This cluster explains what actually happened, what the consent standard is today, and why — despite the repeal — TCPA litigation pressure has not let up and operators still need disciplined consent practices.

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How TCPA Lawsuits Get Built (and Where the Risk Really Lives)

A plain-English field guide for lead-gen operators on how TCPA cases come together, why statutory damages make them attractive to plaintiffs, and what the 2025 vacatur of the FCC's one-to-one consent rule actually changed.

Jun 26, 2026

Frequently Asked Questions

What happened to the FCC one-to-one consent rule?

The FCC adopted a rule that would have required consent to be given to a single, specific caller — directly targeting the lead-gen and comparison-shopping model of shared consent. In January 2025 the Eleventh Circuit vacated the rule, holding the FCC had exceeded its authority, and the FCC subsequently repealed it. The standard reverted to the prior express written consent framework that existed before.

So is consent-sharing fine again?

The specific one-to-one restriction is gone, but that does not make consent a free-for-all. Prior express written consent still applies, the FTC and state regulators still scrutinize how lead-gen consent is obtained, and plaintiffs still sue. The repeal removed one specific rule, not the underlying risk — which is why disciplined, well-documented consent remains essential.

Has TCPA litigation actually slowed down?

No. TCPA filing volume has held roughly steady, and class-action activity remains a live threat. The economics of TCPA litigation — statutory damages per call or text, multiplied across a campaign — keep it attractive to plaintiffs regardless of which specific rules are on or off the books. Plan as if you will eventually have to prove your consent in front of someone skeptical.

The Operator’s Compliance Brief

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The Operator’s Compliance Brief

What changed in lead-gen compliance, and what to do about it. Free, no spam.