Eleventh Circuit Vacates TCPA One-to-One Consent Rule Immediately After FCC Postpones its Effective Date - The National Law Review
The Eleventh Circuit vacated the FCC's one-to-one consent rule for TCPA calls/texts, and the FCC subsequently postponed the rule's effective date, creating immediate regulatory uncertainty for telemarketers.
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 rely on prior express consent. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Not specified in the source; monitor for updates.. 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 (requiring each seller to obtain separate consent) has been vacated by the Eleventh Circuit, and the FCC has postponed the rule's effective date, so the rule is not currently in effect.
Who it affects
All businesses engaged in telemarketing, SMS marketing, lead generation, and debt/insurance dialing that rely on prior express consent.
What you must do
Review current consent practices and prepare for potential reinstatement or alternative compliance; monitor FCC and court actions.
Deadline
Not specified in the source; monitor for updates.
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- Eleventh Circuit Vacates FCC’s One-to-One Consent Rule; FCC Issues Stay - Consumer Financial Services Law Monitor
- FCC Grants Limited One-Year Extension for TCPA Robocall Revocation Rule Compliance - Consumer Financial Services Law Monitor
- New FCC rule on TCPA consent for advertising and telemarketing calls and texts will significantly impact callers who obtain consent from lead generators - Consumer Finance Monitor
- New FCC Rule Affects Consumer Consent for Robocalls and Robotexts - Jones Day
- FCC reinstates “prior express consent” standard for robocalls after Eleventh Circuit vacates 2023 rule - JD Supra