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Phones and the AI receptionist

Entity-specific Do Not Call list

internal do not call list / company do not call list / entity-specific do not call

In short

An entity-specific Do Not Call list is a business's own record of people who asked it to stop calling them. The Telemarketing Sales Rule forbids calling those people, separately from the National Do Not Call Registry, and each violation can bring a civil penalty of $53,088.

The Federal Trade Commission's guide to the Telemarketing Sales Rule calls it the entity-specific Do Not Call provision. A telemarketer may not call a consumer who has asked not to receive more calls from or on behalf of a particular seller. A seller that has been asked not to call also may not have a telemarketer call that person.

Keeping the list falls to the business. The FTC says sellers and telemarketers are responsible for maintaining their own Do Not Call lists, and that calling someone on one can bring a civil penalty of $53,088 for each violation. A seller without distinct corporate divisions may not call that person again even to offer something different.

It runs alongside the national registry, and the two work differently. The established business relationship exemption lets a seller call a customer whose number is on the national registry, but only if that customer has not asked to be on the seller's own list. Telefunders calling for charities are exempt from the national registry provision and must still honor the entity-specific one.

The rule also protects the request itself. Under 16 CFR 310.4, it is abusive to interfere with someone's request to be put on the list, including making them listen to a sales pitch first or charging a fee to honor it.

In practice

A home security company's outside appointment setter calls a past quote request, and the person asks not to be called again. That request has to reach the company's own list. If the company's in-house team calls the same person next month about a different package, the call breaks the rule, because a single seller may not call again even to offer something different.

Not the same as

National Do Not Call Registry
The national registry lists numbers people registered against telemarketing in general. The entity-specific list holds people who asked this particular seller to stop, whether or not they are on the registry.

Why it matters to you

A request to stop can be made to anyone who calls for the business: a salesperson, an outside telemarketer or an AI calling tool. The list only works if every one of those routes feeds it and every outbound call is checked against it. An existing customer relationship does not override the request.

What to ask or check

  1. 01Where are do not call requests recorded, and does every calling tool and outside caller check that list?
  2. 02When an outside company or AI tool hears a request to stop, how does it get back onto the business's list?
  3. 03Could anyone calling for the business make a person listen to a pitch before accepting a request to stop?

What people get wrong

That an existing customer relationship allows the call anyway. The FTC says the established business relationship exemption applies only if the consumer has not asked to be on the seller's entity-specific Do Not Call list.

National Do Not Call Registry

The National Do Not Call Registry is the federal list of numbers telemarketers may not call. Sellers subscribe by area code, and FTC guidance says call lists must be scrubbed against it at least every 31 days. Business to business calls are largely outside the rule, with narrow exceptions.

Telemarketing Sales Rule

The Telemarketing Sales Rule is the FTC rule governing sales calls. Beyond the do not call list, it sets what a caller must say and when they may call: residential calls only between 8am and 9pm local time, and a prompt disclosure that the purpose of the call is to sell something.

Robocall

A robocall is an outbound call that plays a recorded message. The Telemarketing Sales Rule prohibits placing one to sell something unless the person gave express agreement in writing beforehand. The rule covers calls you place. A system that answers calls coming in to you is a different thing.

AI voice calls

An AI voice call uses a synthesized or cloned voice to speak to the person who answers. In February 2024 the FCC confirmed those voices fall under the existing rules on artificial or prerecorded voice, so the same consent requirements apply. The message must also identify your business and offer an automated way to opt out.

Reassigned Numbers Database

The Reassigned Numbers Database is an FCC database that tells a caller whether a phone number has been permanently disconnected since a given date, which means it may now belong to someone else. Querying it before calling on old consent is how a caller qualifies for the FCC's safe harbor for reaching a reassigned number.

Call tracking

Call tracking replaces the phone number shown to a visitor with a substitute number that routes to your real one. Only calls dialed through that substitute are measured. Google assigns a forwarding number when call reporting is on, and Microsoft requires an ad group to have reached 10 clicks and 10 dollars of spend in 30 days.

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