How the FCC’s One-to-One Consent Rule Will Impact Contact Centers

Disclaimer: The articles and contents of this website are provided for informational purposes only and should not be construed as legal advice. The information contained herein does not create an attorney-client relationship and should not be used as a substitute for professional legal consultation. Always seek the advice of a qualified attorney for any legal issues or concerns you may have.

Check out the following resources released by the FCC:

• FCC fact sheet
• FCC announcement outlining new rules
• FCC report and order and further notice of proposed rulemaking

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The Federal Communications Commission (FCC) has scheduled the new TCPA regulations to come into force on January 27, 2025 – and it might be one of the biggest shifts the lead generation market has ever seen.

The gist of the new FCC ruling is as follows: sharing a consumer’s consent for multiple businesses listed on a lead generation form is now prohibited. Instead, individual consent must be obtained for every included business listed on a form. Likewise, come January 27, 2025, robotic texts and calls require individual prior express written consent.

Read on to explore what the FCC update changes for call centers and how to maintain compliance in 2025.

Explore Consent Branches, a Phonexa’s proprietary solution that turns lead generation forms FCC-compliant while connecting opted-in leads to a matching advertiser.

Understanding the One-to-One Consent Rule

It’s not secret that most compliance regulations focus on protecting consumer rights, including their privacy, with the core rules stipulated by the Telephone Consumer Protection Act (TCPA) and STIR/SHAKEN protocols that authenticate called ID, verify the correctness of their phone number, and prevent spoofed calls.

The new one-to-one consent rule is an addition to the existing TCPA regulations, now prohibiting businesses from receiving bundled consent, a practice when a consumer gives consent to dozens and hundreds of advertisers at a time.

The FCC update mandates that businesses, including call centers, must receive prior express written consent for each company they list on a lead generation form. Likewise, they must obtain prior express written consent for robotic texts and calls.

Here are some additional aspects of the new 2025 FCC regulations:

Consumers get control over marketing	If previously consumers were largely unaware of the businesses they granted consent to, now they will manually select every company and understand how exactly this company is going to contact them.
Lead generation forms become detailed	Lead generation forms will require including all offered brands along with their names, logotypes, and how these brands are going to contact the consumer
Consent records are now mandatory	Businesses must now keep consent records to ensure compliance. This also simplifies reporting and compliance audits.

The biggest change for call centers is the reduced volume of calls and their higher price. Since consumers now consciously choose businesses that they want to contact, these businesses will get high-intent leads.

Stay FCC-compliant with Consent Branches, Phonexa’s proprietary solution for managing one-to-one consent on lead generation forms. Effortlessly integrate it with Smart Tree technology to streamline compliance and boost your lead generation efforts.

How the 2025 FCC Update Will Impact Call Centers

There are several more implications for contact centers:

Increased costs	From developing one-to-one consent forms to storing consent records, an increase in consent complexity leads to an increase in operational costs. Legal staff and marketers need more time to ensure FCC and TCPA compliance.
Tailored experiences	Since it’s only reasonable to include a limited number of brands on a lead generation form, contact centers have to make sure they offer businesses that fully match customer expectations.
Rigorous risk management	Implementing new compliance strategies means additional risks for contact centers and therefore makes risk management more important.

Overall, the FCC update makes marketing more customer-oriented at the expense of the businesses that want to acquire these customers.

And there’s nothing wrong with that: contact centers that can tailor their offering to different groups of consumers will get higher engagement and more sales, while those used to casting a wide net may have to revamp their marketing strategies to stay competitive.

One-to-One Consent Challenges for Contact Centers

Decrease in lead volume	As lead generation becomes granular, contact centers may experience a decrease in lead volume, especially ones that abuse shared consent. However, the quality of leads also grows, so compliant contact centers might find a proper quality-quantity balance.
Changes in marketing strategies	Higher compliance and consumer costs require a change in marketing strategies. Contact centers have to spend more on acquiring a caller—for example, cherry-picking the brands they want to offer – but they are also likely to have higher conversion rates.
Uncertainty	The TCPA requirement for consent to be “logically and topically related” to the transaction is somewhat vague, so contact centers may have to determine what specific strategies satisfy the new FCC regulations.

One-to-One Consent Benefits for Contact Centers

Fostering long-term relationships	Full disclosure regarding the brands that are going to contact the consumer will surely build trust and foster meaningful relationships with consumers.
Increased customer satisfaction	Meaningful marketing contacts will make consumers satisfied – and satisfied consumers spend more, potentially becoming your loyal clients and even brand advocates.
Outpacing laggard competitors	Big market shifts are always a time of opportunity. FCC-compliant contact centers can win some market share from competitors who delay implementing the one-to-one lead generation forms.

It’s becoming much more important to build a one-to-one relationship with every client, prioritizing their lifetime value over immediate profits. It takes time, but it also pays off immensely for FCC-compliant contact centers.

Phonexa’s Consent Branches To Acquire FCC-Compliant Leads

Whether you generate traffic for your own contact center or sell it to advertisers, there is no better solution to ensure one-to-one consent than Phonexa’s proprietary Consent Branches, an acquisition technology that smoothly matches consumers with brands while granting FCC compliance.

Here’s how Consent Branches operate:

1. Lead generators send non-PII pings to the system: First, the lead generators (affiliates, publishers, etc.) send partial data about their leads to Phonexa – the so-called non-PII pings, ones that don’t contain any personally identifiable information but still give advertisers an idea of what consumers are offered. Non-PII pings may include the consumer’s ZIP code, device type, and other general info.
2. Phonexa offers consumers a one-to-one consent lead generation form that includes matching brands: Phonexa matches the non-PII pings with potential buyers who place their bids based on the non-PII info and put these buyers on a lead generation form.
3. Leads are sold to the chosen advertisers: The selected brands – ones granted one-to-one consent – receive the rest of the consumer’s personal details so they can make a marketing call to this consumer.

Ensure FCC-compliant lead generation for your business with Consent Branches – Phonexa’s proprietary one-to-one consent solution integrated into Phonexa’s Smart Tree technology.

Custom vs. Generic Consent Language on Lead Generation Forms

With Phonexa, you can either enable Consent Branches with your own lead generation forms using API, or you can build custom one-to-one consent forms with our form builder. Either option is good, and you can also choose the consent language: custom or genetic.

Custom Consent Language

With custom consent language, every brand is represented with a unique consent language that includes all consent-necessary details: the company’s name, logo, and what marketing channel they want to authorize with the consumer (text messages, phone calls, SMS, etc.).

Here’s how custom consent language looks on a lead generation form:

As you can see, the consent language includes the company’s logo, name, the consumer’s phone number for which they receive consent, and the marketing channels they want to authorize. For different companies, these details are different, and the consumer can manually select between the bands.

Generic Consent Language

Generic consent language is a simpler yet still FCC-compliant solution. Instead of crafting individual disclosure for every brand, you can put one generic language on a form IF all the brands satisfy what’s written.

Here’s how generic consent language looks on a lead generation form:

As you can see, there’s a little trick: the “Select All Providers” button. It’s fully compliant, but it leaves a chance that the consumer won’t bother choosing a brand individually but selects all of them in one click. This is a great acquisition strategy under the new TCPA rules.

FCC and TCPA-Compliant Lead Generation with Phonexa

Phonexa offers what most digital marketers need: an all-in-one performance marketing software suite that ensures in-depth insights into consumers and full compliance. Whether you are a lead generator, advertiser, or an affiliate network, Phonexa makes the game so much safer and easier.

Here are the eight proprietary solutions you get at a single price (online price calculator):

Explore Consent Branches, a Phonexa’s proprietary solution that turns lead generation forms FCC-compliant while connecting opted-in leads to a matching advertiser.

Frequently Asked Questions

What is the FCC one-to-one consent update?

The FCC one-to-one consent update is an update to the Telephone Consumer Protection Act (TCPA), which came into force on January 27, 2025, to mandate obtaining prior express written consent for robotic calls—ATDS calls—and texts.

How will the new FCC one-to-one consent rules affect lead generation?

The likeliest outcome is that the leads will become harder and more expensive to generate. This doesn’t mean affiliates’ and advertisers’ profits will plummet, but marketers will have to learn to capture individual consent before contacting consumers.

What is the best strategy to generate phone calls after the FCC one-to-one consent update?

The overall best lead generation strategy in the new consent era is to focus on the relevance and value of the brands you offer to a specific consumer while providing them with detailed information about these brands and their marketing practices.