The FCC One-to-One Consent Rule, Explained

For years, a single checkbox on a comparison-shopping site could be used to claim a consumer consented to be called by dozens or hundreds of "marketing partners." The FCC's move toward one-to-one consent was aimed squarely at that practice, and it reshapes how lead-based calling has to work.

What one-to-one consent means

The principle is that prior express written consent should be given to one specific, identified seller at a time — not to an open-ended list of unnamed partners. A consumer agreeing to hear from "Company A" hasn't agreed to hear from Companies B through Z, even if they all bought the same lead.

Who it affects most

Lead generators and lead buyers feel this most acutely. A lead sold to multiple buyers, each relying on the same generic consent, is exactly the fact pattern the rule targets. If you buy leads, the question "who exactly did this consumer consent to hear from" becomes central to whether you can legally call them.

What to do about it

• If you generate leads, capture consent that names the specific seller(s) who will contact the consumer.
• If you buy leads, demand proof of seller-specific consent and keep it — a vague partner-list consent may not protect you.
• Re-examine any comparison-site or co-registration lead sources against the one-to-one standard.
• Scrub every purchased list anyway; consent problems and DNC problems compound in bought data.

We cover the buying side in TCPA compliance for bought leads and consent basics in consent types explained.

Scrub your lead lists free before you dial them.

General information, not legal advice. Rules in this area are evolving — confirm the current requirements with counsel.