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The one-to-one consent rule: what happened, and what lead buyers still need

Updated October 4, 2026

In December 2023 the FCC adopted a rule that would have limited each shopper's consent to one seller at a time. A federal appeals court struck it down before it took effect. The older standard is back, but the problem the rule was aimed at still shows up in lawsuits over purchased leads.

What was the one-to-one consent rule?

The FCC adopted it on December 13, 2023. It changed the definition of prior express written consent, the consent needed for sales calls and texts made with an autodialer or a prerecorded or artificial voice. The rule had two main parts:

• One seller at a time. A shopper's consent could cover only one identified seller. A comparison site could still offer several sellers, but the shopper had to choose each one separately, for example with a checkbox next to each name.
• Related calls only. The calls and texts had to be "logically and topically associated" with the website where the shopper gave consent. A shopper who asked for auto quotes could not have been called about something unrelated.

The rule was set to take effect on January 27, 2025.

What was the "lead generator loophole"?

That was the FCC's name for the practice the rule targeted. A shopper filled out one form and pressed one button. The fine print, or a link next to it, named a long list of "marketing partners." Lead sellers treated that single click as consent for every company on the list. In the FCC's view, one form could lead to calls from tens or even hundreds of companies the shopper had never heard of.

The one-to-one rule would have ended that by making each seller get its own consent. A trade group of insurance marketers, the Insurance Marketing Coalition, challenged it in court.

Is the one-to-one consent rule still in effect?

No. It never took effect. Here is the timeline:

• January 24, 2025. The FCC postponed the effective date. The same day, the U.S. Court of Appeals for the Eleventh Circuit decided Insurance Marketing Coalition v. FCC and vacated the rule.
• The court's reasoning. The TCPA doesn't define "prior express consent," so the court gave the phrase its ordinary meaning: a person clearly agrees, before the call, to receive it. The court held that the FCC went beyond its authority by adding conditions the statute doesn't contain, such as one seller at a time.
• April 30, 2025. The court issued its mandate, and the vacatur took effect.
• July 14, 2025. The FCC issued an order deleting the vacated language and restoring the earlier definition in its rules.

You may still find pages that say the rule took effect in January 2025. It didn't.

What prior express written consent still requires

The restored federal definition is the one that applied before 2023. For a sales call or text made with an autodialer or a prerecorded or artificial voice, the consent has to be:

• A written agreement signed by the shopper. An electronic signature on a website form counts when federal or state law recognizes it as a signature.
• Clear about who. It has to clearly authorize the seller to deliver those calls or texts.
• Clear about the number. It includes the phone number the shopper agrees to be contacted at.
• Clear and conspicuous. It tells the shopper that signing authorizes calls using that technology, and that they don't have to agree as a condition of buying anything.

Federal rules no longer limit consent to one seller at a time. They still require the consent to authorize the seller that is calling. Some states also have their own telemarketing laws with stricter consent rules, so check with counsel about the states you call into.

Why buyers still want the seller named on the form

The rule is gone, but the risk it was meant to address is still there for buyers. If the form a shopper filled out doesn't name you, and doesn't link to a list that included you, your record may not show consent to hear from you. Two cases turned on exactly that gap. Class certification and settlements are not findings of liability.

Ward v. Liberty Mutual (D. Mass., June 2026). The leads came from All Web Leads, which got them from Next Level Media's website. That site didn't list Liberty Mutual. The court certified a class of about 20,000 people, with exposure of about $30 million. Liberty Mutual sued All Web Leads for $1.36 million, and that suit settled.

Mantha v. QuoteWizard (D. Mass.). The consent pages on partner websites didn't name QuoteWizard. The case ended in a $19 million settlement covering 66,693 phone numbers.

Neither case depended on the one-to-one rule. Both turned on whether the form covered the company that called. For more on how these claims work, read TCPA risk in purchased insurance leads.

What to ask for now

When you buy leads, ask the vendor for these, for every lead:

1. The consent text, word for word. Read who it names before you dial.
2. Proof that it covers you. Your agency named on the form, or a partner list linked from the form. If it's a list, ask for a dated copy showing your name was on it when the shopper agreed.
3. A third-party record of the form. A TrustedForm certificate or Jornaya LeadiD, which you keep in your own account. See TrustedForm vs. Jornaya.
4. A quote form as the source. The shopper asked about insurance, not a prize, survey, or job offer.
5. The contact methods covered. Calls, texts, and any dialer or prerecorded voice you plan to use.

To check a certificate yourself, follow how to check a TrustedForm certificate. For the rest of the vendor conversation, see questions to ask an insurance lead vendor.

VeroQuote sends the consent text word for word with every lead, so you can see who the shopper agreed to hear from before you call.

This guide is general information, not legal advice.