FCC One-to-One Consent: What Publishers Need to Know for 2025

The FCC's new one-to-one consent rules represent the most significant change to telemarketing regulations in years. Publishers must understand and implement these changes to continue operating compliantly.

What Changed

Previously, consumers could consent to receive calls from multiple sellers through a single checkbox. The new rules require separate, specific consent for each seller who will contact the consumer. This 'one-to-one' consent requirement fundamentally changes how lead forms must be structured.

Implementation Timeline

The rules took effect January 27, 2025. Publishers should already have updated their forms and processes. Networks are actively rejecting leads that don't meet the new consent standards.

Form Design Requirements

Each seller that will receive the lead must be clearly identified at the point of consent. Pre-checked boxes are explicitly not permitted. The consumer must take an affirmative action to consent to each seller.

Disclosure Language

Your disclosure must clearly explain that the consumer is consenting to receive calls and/or texts, that these communications may use automated technology, and that consent is not a condition of purchase.

Record Keeping

Maintain detailed records of consent for every lead: timestamp, IP address, exact consent language shown, which sellers the consumer consented to, and the URL where consent was captured. Store records for at least five years.

Enforcement and Liability

The TCPA creates a private right of action, allowing consumers to sue for $500 per violation, trebled to $1,500 for willful violations. Class action lawsuits are a particular risk for high-volume publishers.