Guides

Can you call aged insurance leads? Consent, DNC, and what to check

Updated October 4, 2026

Often, yes. The age of the lead matters less than what its record shows: what the shopper agreed to, who they agreed to hear from, whether they've said stop since, and the Do Not Call rules where they live.

What are aged leads?

Aged leads are leads sold days, weeks, or months after the shopper filled out the form, usually for less than a realtime lead. Some were sold to other agents first, so ask whether each one is exclusive or shared. Ages vary by vendor. Our aged leads are 7 to 30 days old.

Does consent expire?

Neither the TCPA nor the FCC's rules put an expiration date on consent. Some federal courts have said consent doesn't lapse just because time passes, and lasts until the shopper clearly revokes it (for example, Walintukan v. SBE Entertainment Group, N.D. Cal. 2018).

That isn't the whole answer. Another court noted that a gap of many years might raise a question of implied revocation, but didn't decide it (Advantage Healthcare v. DNA Diagnostics Center, N.D. Ill. 2019). Consent also has a scope: it covers what the shopper asked about, so a form for auto quotes is a weak basis for a call about something else.

And people forget. A shopper who doesn't remember the form is more likely to complain, and each call or text without valid consent can cost $500, or up to $1,500 if willful or knowing (47 U.S.C. § 227(b)(3)). The law on stale consent isn't settled, and no rule makes a lead safe for a set number of days. If you call older leads at volume, have a TCPA attorney review your process.

You may have read that old consents would all expire in January 2025. That came from the FCC's one-to-one consent rule, which never took effect. The Eleventh Circuit vacated it in Insurance Marketing Coalition v. FCC in January 2025, and the FCC repealed it later that year.

Do aged leads need a Do Not Call scrub?

Yes. Federal rules bar telemarketing calls to numbers on the National Do Not Call Registry unless an exception applies, and you must scrub against a copy of the registry that's no more than 31 days old (47 C.F.R. § 64.1200(c)(2)).

The exception that matters for leads is a signed, written agreement in which the shopper agrees to be contacted by that seller. Consent from a quote form can cover a number on the registry, but only if it's valid prior express written consent that covers you. Consent that names a different company doesn't.

Don't lean on the "established business relationship" exemption either. A shopper's inquiry creates one for three months, but with the company they asked. As a 2021 National Law Review article describes it, the FTC's position is that a lead buyer can't borrow the lead generator's relationship.

Some states keep their own Do Not Call lists, including Florida and Texas. Scrub against those for shoppers who live there, and against your own internal do-not-call list.

When the shopper says stop

A shopper can revoke consent at any time, by any reasonable means: replying STOP, saying so on a call, or sending an email. Under FCC rules in effect since April 11, 2025, you have to honor a revocation within a reasonable time, no more than 10 business days. Do-not-call requests have the same limit (47 C.F.R. § 64.1200(d)(3)).

With aged leads, the shopper may have told someone else to stop before you bought the lead. Ask your vendor whether it removes opt-outs it receives before it sells a lead again.

What to check on each aged lead before you dial

1. The original consent text, word for word. Does it cover calls and texts, autodialed or prerecorded calls if you use them, and numbers on Do Not Call lists?
2. Who it names. Your agency, by name or through a partner list linked from the form, at the time the shopper pressed submit.
3. The consent date and time. It tells you how old the consent is and which rules applied that day.
4. The certificate or token. A TrustedForm certificate or Jornaya LeadiD from the original form. ActiveProspect's developer docs say a TrustedForm certificate lasts 90 days for a lead unless someone retains it, so retain yours early, and ask whether certificates on older leads were retained.
5. The source. An insurance quote form, not a survey, sweepstakes, or free-sample page.
6. Your scrubs. The National Do Not Call Registry, state lists, and your internal list. The FCC's Reassigned Numbers Database can also tell you whether a number was disconnected after the consent date, a sign it may belong to someone else now.
7. State rules. Federal rules allow telemarketing calls from 8 a.m. to 9 p.m. in the shopper's local time. Florida and Oklahoma cut that to 8 a.m. to 8 p.m., limit sales calls to three per 24 hours on the same subject, and require prior express written consent for automated calls. Other states have their own rules, and they change.

How to work aged leads

Call inside the shopper's local calling hours. Open with what they asked for and roughly when, so they can place you. Use the details on the record, like current carrier and renewal date, to make the call worth their time. Text only if the consent covers texts. When someone says stop, log it and stop calls and texts alike.

If a lead is missing the consent text, the consent date, or the certificate or token, don't dial it. Ask the vendor for the record first. For more on what to ask before you buy, see 12 questions to ask an insurance lead vendor.

This guide is general information, not legal advice.