The TCPA’s one-to-one consent rule is no more—what that means for you

An FCC rule set to enhance consumer protection for phone sales was struck down.

Written by:
Edited by: Alix Langone
Updated Jan 29, 2025
3 min read
TCPA one-to-one consent update

Consumers in the U.S. came close to having fewer unwanted robocalls this week, but a new rule aimed at limiting those pesky spam calls was struck down at the last minute. 

The Federal Communication Commission (FCC) initially postponed its new Telephone Consumer Protection Act (TCPA) regulations designed to enhance consumer protections regarding phone sales, but was ultimately struck down by the Eleventh Circuit Court of Appeals on January 24, 2025. Specifically, the Court objected to the TCPA’s one-to-one consent rule.

Without the FCC’s one-to-one consent rule in place, you’ll have to keep reading the fine print to avoid opting into unwanted phone communications from businesses. Let’s break down how this TCPA rule ended up on the chopping block and how these changes might impact you—especially if you're interested in clean energy.

The rule could have created a shift in the solar industry, which has garnered a less-than-stellar reputation from its historical reliance on lead generation and sales-only companies to find new sales prospects they would then, in turn, funnel haphazardly to multiple businesses.

With the one-to-one rule being eliminated, homeowners interested in going solar have to remain vigilant when it comes to unknown numbers showing up on their phones. It’s still important to do your research and speak to multiple solar installers before signing any type of agreement, especially with a company that may have called you out of the blue.

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Key takeaways

  • The FCC postponed new TCPA regulations on January 24, 2025, the day before its effective date.

  • The TCPA’s one-to-one consent rule, which would’ve prevented businesses from using a single consent agreement across sales partners, was a point of contention among industry players. 

  • The Insurance Marketing Coalition (IMC) filed a petition challenging the TCPA’s one-to-one consent rule. 

  • The Eleventh Circuit Court of Appeals vacated the one-to-one consent rule, meaning it’s no longer legally enforceable.

The TCPA was designed with consumers in mind. Under the changes to this act, businesses across industries must implement consumer protection measures like displaying company information on caller ID and disclosing where they sourced customer phone numbers. 

Arguably the most impactful (and controversial) change initially included in the TCPA was the one-to-one consent rule, which would’ve required consumers to identify the company to whom they were giving consent to call and text them.

Under the one-to-one consent rule, consent would only be between you and the company you opted into communication with—it wouldn’t extend to that company’s sales partners. Instead, each sales partner would also need to obtain your express consent before calling or texting you. 

The one-to-one consent rule may seem like a no-brainer as a consumer, but it sparked controversy among businesses that apply a single consent agreement across all sales partners.

The FCC postponed the one-to-one consent rule’s effective date on January 24, 2025, just one business day before it was set to take effect. This decision followed a petition filed by the Insurance Marketing Coalition (IMC) challenging TCPA’s one-to-one consent rule. Later that day, the Eleventh Circuit Court of Appeals vacated the rule, rendering it no longer legally enforceable. 

Ultimately, the Court decided that the FCC “exceeded its statutory authority” with the one-to-one consent rule because its restrictions “conflict with the ordinary statutory meaning of ‘prior express consent.’” Essentially, the Court ruled that the “common law concept of consent” was sufficient, allowing businesses to continue operating under the existing framework.

You probably won’t receive more telemarketing calls or text messages than you’re used to because the prior consent rule was reinstated in the wake of the vacated one-to-one consent rule. Companies still need your consent, but be aware that a single click might opt you into communication from multiple businesses.

Be especially careful when engaging with solar businesses online. Lead generation and sales-only companies are known to present themselves as solar companies to collect and sell customer data; opting into communication with one of these organizations can lead to unwanted sales calls.

Currently, it’s unclear what the FCC will do next. The Commission didn’t contest the Court’s decision to vacate the one-to-one consent rule, but that doesn’t mean further review is off the table. Pressure from consumer groups largely prompted these proposed changes in the first place, and it’s reasonable to expect continued advocacy for stronger protections against unwanted communication.

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