The Federal Communications Commission (FCC) was set to rock the lead generation industry with a key amendment to the Telephone Consumer Protection Act (TCPA) in early 2025. This amendment, the one-to-one consent requirement, would have reshaped how lead buyers, sellers, and publishers operate in the digital space.

But at the last minute, everything was halted. However, this is not a time to take a victory lap or slack on TCPA compliance. New rules have still been implemented in the wake of the end of the proposed one-to-one consent requirement, and stricter regulations are perpetually being discussed.

By the time you’re finished with this guide, you’ll be well-equipped to steer your FCC lead generation practices toward a compliant and prosperous future with the help of TrustedForm.

FCC lead generation ruling

Originally scheduled for January 27, 2025, the FCC’s proposed one-to-one consent rule was officially canceled only days before it was set to take effect.

This rule would have required consumer consent to be explicitly tied to the specific seller contacting them, a move aimed at increasing transparency and tightening data sharing/data selling across lead generation and telemarketing.

But at the eleventh hour, two key developments brought the rule to a halt. On January 24, 2025, the FCC issued a formal 12-month delay, and the Eleventh Circuit Court of Appeals ruled in favor of the Insurance Marketing Coalition, declaring that the FCC lacked the authority to redefine consent under TCPA regulations.

The result? The one-to-one consent requirement has been struck down and will not move forward.

2025 FCC lead generation regulations

While the one-to-one consent rule was ultimately withdrawn, the FCC’s separate 2025 TCPA updates around consent revocation that took effect on April 11, 2025, went forward and carry significant weight. 

The FCC has made it clear: Consumers should have more options and ways to revoke consent to be contacted by phone or text message. This shift impacts how lead buyers, sellers, and aggregators must structure their consent disclosures and compliance strategies.

Key consent revocation rules

  • Any reasonable method is valid: Companies need to more widely consider consumers’ consent revoke requests to future calls or text messages could be received through multiple or unrelated channels, such as SMS, email, voicemail, live calls, or even a casual “stop contacting me.” If the intent is clear, to stop contacting that number, the revocation request must be acted upon.
  • 10 business days to act: The window for processing opt-outs has been reduced from 30 days to “no more than 10 business days,” requiring lead systems to act faster and coordinate more efficiently.
  • Confirmation message restrictions: Businesses may send one confirmation message, but it must:
    • Be sent within 5 minutes
    • Contain no marketing or promotional content
    • Serve only to confirm the opt-out
  • Delayed scope expansion: A broader requirement—treating any opt-out, including those from an “informational” or transaction message, as revocation from all future communications from the same sender—was originally delayed until April 11, 2026 and has now been delayed again to January 2027 (find more information about this new development below). This gives lead gen operations more time to build the necessary infrastructure.

For the FCC lead generation ecosystem, these changes signal a transition from broad, loosely enforced practices to a more responsive, consumer-directed, accountable model. Marketers and data partners who don’t modernize their revocation handling risk losing not just legal ground, but credibility and channel access.

The path forward is clear: Consent must be transparent, and revocation must be respected, no matter how it’s delivered.

FCC and lead generation: What to consider in 2026

As businesses look ahead to 2026, the FCC’s position on TCPA compliance remains clear: While some timelines have shifted, expectations around consent, transparency, and responsiveness have not.

In January 2026, the FCC delayed the effective date of the so-called “revocation-all” requirement—which would have required a single opt-out request to apply across all unrelated calls and texts (“informational” or transaction messages) from the same sender—until January 31, 2027. However, this delay does not roll back other key consent revocation rules already in effect. 

Businesses must still:

  • Accept any reasonable method of revocation (such as “STOP,” “QUIT,” or similar requests)
  • Process opt-outs within 10 business days
  • Ensure confirmation messages are limited and non-promotional

For lead buyers and publishers, 2026 should be treated as a preparation year: Documenting consent rigorously, ensuring revocation signals can be captured across channels, verifying that leads are human-generated, and aligning internal systems ahead of the 2027 expansion. 

Companies that use this time to modernize workflows and strengthen proof of consent will be best positioned to reduce risk, avoid enforcement scrutiny, and adapt quickly as FCC and lead generation rules continue to evolve.

FCC lead generation compliance tips for lead buyers

1. Always obtain verifiable and documented consent

Even without the one-to-one consent rule, generic opt-ins won’t cut it. Lead buyers should demand proof that consumer consent was clearly tied to the buyer’s brand and collected via compliant, transparent methods. Lead sellers must use tools and processes that capture:

  • Explicit opt-in checkboxes
  • Source URLs
  • Timestamps and session data
  • Clear disclosures

This is the single most important step in the process because of the value and security it brings. In a webinar with ActiveProspect, Alexandra Krasovec, Partner at Manatt, Phelps & Phillips, LLP, echoed this sentiment, “If you are making marketing outreach, again, get that heightened prior express written consent. It is the laundry list of things that you have to have, but if you obtain it, that is “as good as gold.”

2. Only work with compliant lead-generation content publishers and sources

Lead buyers should also evaluate and regularly monitor their publisher’s compliance with the FCC’s TCPA rules. This step should help establish, foster, and maintain a sustainable partnership built on mutual compliance adherence.

Lead buyers should:

  • Regularly audit partner consent disclosure language and opt-in flows
  • Require third-party compliance verification (like TrustedForm certificates)
  • Set performance standards and terminate non-compliant relationships

3. Establish clear revocation protocols across all channels

Revocation can come through any reasonable method, so beyond text message, potentially email, voicemail, live chat, or even social media. Lead buyers should have workflows in place to receive, review, decide, process, and honor opt-outs from multiple sources.

FCC lead generation compliance tips for lead publishers

1. Reinforce consent processes

Lead publishers have a shared responsibility to present, capture, and document consumer consent to contact transactions in various lead generation models. To address compliance, lead seller publishers must refine their consent-gathering design and pathway to be transparent, easy to understand, and documented every step of the way.

2. Trust, TrustedForm

While the FCC’s one-to-one consent requirement is no longer moving forward, TrustedForm Verify remains essential for businesses committed to maintaining a high standard of consent-to-contact compliance.

Verify helps mitigate risk by maintaining that prior express written consent is properly presented and documented in a digital format, making it easier to audit and scale with confidence.

With TrustedForm Verify, businesses can:

  • Evaluate compliance consistently, reducing the risk of human error, especially when managing multiple lead sources or vendors
  • Save time and boost productivity through automation, minimizing the need for manual reviews
  • Centralize the data needed to monitor and assess vendor performance against your compliance standards

Even without the one-to-one consent rule, TrustedForm Verify continues to offer a powerful edge for businesses that view compliance not as a burden, but as a strategic advantage.

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Final thoughts

The FCC’s last-minute reversal on the one-to-one consent rule may feel like a reprieve, but it’s not a free pass. If anything, it’s a reminder that regulatory scrutiny is intensifying, and lead generation practices are under the microscope.

The 2025 and 2026 TCPA updates make one thing clear: text message revocation is the new battleground for compliance. Businesses must be prepared to recognize, process, and honor opt-outs quickly, accurately, and across every channel. Implementing up-to-date revocation processes is mandatory, but a modern infrastructure of compliance starts before the first call or text is even sent.

For lead buyers, compliance starts with holding publishers and vendors to higher standards and demanding documented, verifiable consent. For lead sellers and publishers, it means rethinking how consent is gathered and communicated, making it clear, transparent, and record-keeping audit-ready.

And while the regulatory environment continues to shift, one thing hasn’t changed: compliance is a competitive advantage. Companies that embrace it, invest in scalable tools like TrustedForm Verify, and build consumer-first practices into every stage of the lead journey will be the ones that earn trust, and grow because of it.

Take the first step with TrustedForm Verify today and help protect your business with the highest standard for independent proof of consent. 

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DISCLAIMER: This page and all related links are provided for general informational and educational purposes only and are not legal advice. ActiveProspect does not warrant or guarantee this information will provide you with legal protection or compliance. Please consult with your legal counsel for legal and compliance advice. You are responsible for using any ActiveProspect Services in a legally compliant manner pursuant to ActiveProspect’s Terms of Service. Any quotes contained herein belong to the person(s) quoted and do not necessarily represent the views and/or opinions of ActiveProspect.

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