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Phones and the AI receptionist

National Do Not Call Registry

do not call list / DNC registry / national registry / scrubbing a call list

In short

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.

Start with the part most people get backwards. The registry is not a list you consult before dialing. It is a list you subtract from your own. The FTC puts the obligation on sellers and telemarketers to delete registered numbers from their calling lists, and calling anyone whose number is in the database is prohibited.

Access works by area code. A company registers, certifies who it is, and pays a fee if it wants more than five area codes of data. The fee is worth understanding as a mechanism rather than a number, because it moves: under the Do-Not-Call Registry Fee Extension Act of 2007, the annual fees rise with the change in the consumer price index, unless that change is under 1 percent, in which case they are not adjusted. Some access is free. Charities and political organizations that want to suppress calls voluntarily pay nothing, and telemarketers can work under a seller client's subscription account number at no cost.

Then the 31 days, where the plain-language guidance and the rule text say slightly different things. The FTC's guidance is flat: update your call lists at least every 31 days. The rule itself frames it as a condition of the safe harbor, which asks for a version of the registry obtained no more than thirty-one days before the call, plus records documenting the process. In practice you treat it as the deadline. What the rule adds is that keeping the records is part of the protection.

In practice

Two exemptions do most of the work. An established business relationship lets you call for 540 days after a purchase, rental, lease or financial transaction, and for 90 days after someone enquires or applies. Those are the periods in the current rule, and they are stated in days rather than months for a reason: count them. Written permission is the other route, and it has to name who may call. Neither exemption removes the need to keep your own internal do not call list.

Not the same as

A ban on calling
It restricts unsolicited sales calls to registered consumer numbers. Calls under an exemption are still allowed.
Your own do not call list
People who ask your business specifically to stop must be recorded and honored separately.

Why it matters to you

Most businesses assume this catches them, and many assume it does not. Both are expensive. The FTC states that business to business calls are not covered by the rule, unless they involve retail sales of nondurable office or cleaning supplies, or solicit sales or charitable contributions from employees. So a company selling to other companies is usually outside it, while the same company running a consumer campaign is squarely inside it. Violations carry civil penalties per call, set by the FTC and adjusted over time, which is what turns a list-hygiene problem into a serious one.

What to ask or check

  1. 01When was our calling list last scrubbed, and can we show the records?
  2. 02Are we relying on an exemption, and can we prove the date it started?
  3. 03Is this campaign aimed at consumers or at other businesses?

What people get wrong

That the registry is something you check a number against before calling. The obligation runs the other way: you obtain the list and remove those numbers from your own.

Red flags

  • A calling list nobody can date, or a scrub nobody kept records of.
  • An established business relationship claimed with no record of when it started.
  • A supplier who treats a consumer campaign as exempt because the business itself sells to other businesses.

Who owns it

The seller carries the obligation. Using an outside telemarketer does not move it, which is why the rule also reaches people acting on a seller's behalf.

Where you will see it

In outbound calling processes, bought lead lists, and any proposal for a phone campaign aimed at consumers.

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.

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.

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.

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.

STIR/SHAKEN

STIR/SHAKEN is how phone carriers sign outbound calls so the receiving network can tell the caller ID was not faked. The signature is your provider attesting to the accuracy of the number it is sending. Congress required it on internet protocol networks and asked only for reasonable measures elsewhere.

Caller ID spoofing

Caller ID spoofing is sending a number other than the line you are calling from. The federal prohibition is not about the technique. It applies to transmitting misleading or inaccurate caller identification information with the intent to defraud, cause harm, or wrongfully obtain anything of value.

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