FCC One-to-One Consent Rule (2025–2026)

Before January 2025, lead generation companies could present a single consent form with a disclosure that the consumer's information would be shared with 'up to 50 marketing partners' — all named in a scroll-down list. A single submission granted all listed companies the right to make automated calls. After January 2025, each company requiring consent must have its own distinct, clearly identified consent request that is logically and topically related to the website or app where it is presented.

The FCC requires that consent be obtained in a context that is logically and topically related to the product or service being marketed. A car insurance website may collect consent to receive calls from car insurance providers — but not from mortgage companies, home security firms, or other unrelated sellers. This effectively prohibits the aggregated lead generation model that previously powered large portions of the US telemarketing industry.

If your organisation purchases leads from third-party lead generators, you must verify that each lead has given direct, one-to-one consent specifically naming your company. The seller's assurance that consent was obtained is insufficient — if the consent form did not specifically name your organisation, those leads cannot lawfully be auto-dialed. Call centres should obtain and retain copies of the original consent forms for leads purchased from third parties.

Compliant consent collection now requires: (1) a separate, clearly visible consent checkbox for each company that will be calling; (2) the company's name stated clearly adjacent to the checkbox (not in a linked PDF or scroll list); (3) a clear description of what the consumer is consenting to; (4) no pre-checked boxes; and (5) no tying consent to a purchase or form submission. First-party leads — where your own website collects consent specifically naming your company — are the safest basis for automated outbound campaigns.