Eleventh Circuit Vacates FCC’s One-to-One Consent Rule; FCC Issues Stay - Consumer Financial Services Law Monitor
The Eleventh Circuit vacated the FCC's One-to-One Consent Rule, and the FCC issued a stay, meaning the rule is currently not in effect.
Aforeworn detected this change in the Telemarketing & TCPA Compliance space on August 23, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. All businesses engaged in telemarketing, SMS marketing, lead generation, and debt/insurance dialing that were preparing to comply with the One-to-One Consent Rule. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Not specified in the change text.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Telemarketing & TCPA Compliance continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
The One-to-One Consent Rule, which required prior express written consent from each consumer for each seller, has been vacated by the Eleventh Circuit and the FCC has issued a stay, so the rule is not currently enforceable.
Who it affects
All businesses engaged in telemarketing, SMS marketing, lead generation, and debt/insurance dialing that were preparing to comply with the One-to-One Consent Rule.
What you must do
Review current consent practices and determine whether to continue with one-to-one consent as a best practice, but no immediate compliance action is required for the vacated rule.
Deadline
Not specified in the change text.
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- Eleventh Circuit Vacates TCPA One-to-One Consent Rule Immediately After FCC Postpones its Effective Date - The National Law Review
- FCC reinstates “prior express consent” standard for robocalls after Eleventh Circuit vacates 2023 rule - JD Supra