Guide
Do I Need a SAN to Scrub My List?
Do I need a Subscription Account Number (SAN) to scrub my calling list?
Short answerTo scrub against the National Do Not Call Registry, yes -- and a seller making telemarketing calls to consumers must hold registry access for every area code it calls, whether or not a vendor runs the scrub. That includes NumberBroom's federal Registry check, which runs only under your own SAN and is included free on lists of up to 1,000 numbers. A SAN is not required for carrier-level phone validation (line type, active status) or for a TCPA litigator scrub -- those run against different data entirely, which is why NumberBroom runs both with no SAN, no account setup, and no sales call.
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The Subscription Account Number question stalls more small operators than any other step in setting up a compliant calling program, and it stalls them for a specific reason: the SAN only gates one of the checks a clean list actually needs, but vendors that sell registry access tend to put it at the very front of onboarding -- before you've even seen a price.
What a SAN actually controls
A SAN is a credential the FTC issues to a seller who subscribes to the National Do Not Call Registry. It authorizes direct access to registry data -- the list of numbers that have asked not to receive telemarketing calls. That's the entire scope. It says nothing about whether a number is a working mobile line, whether it's VoIP, or whether its owner is a serial TCPA plaintiff.
| Check | What it tells you | Requires a SAN? |
|---|---|---|
| National DNC Registry scrub | Whether the consumer opted out of telemarketing calls | Yes |
| Carrier-level validation | Line type (mobile, landline, VoIP) and active status | No |
| TCPA litigator scrub | Whether the number is tied to a known serial filer | No |
| State DNC registries | Whether the consumer opted out of a state-level list | Varies by state -- several require their own registration |
| Internal do-not-call list | Whether your own business was asked to stop | No -- this is your own record, not FTC data |
Only the first row is gated by a SAN. The other four run on entirely different data, so a vendor offering carrier validation and a litigator check has no legitimate reason to ask for one before you can start.
What a SAN actually costs
The FTC sets registry fees by fiscal year, and a new fiscal year starts on 1 October. The fees change on 1 October 2026, when fiscal year 2027 begins, so both schedules are below:
| Fee | Until 30 Sep 2026 | From 1 Oct 2026 |
|---|---|---|
| First 5 area codes | Free | Free |
| Each additional area code, per year | $82 | $85 |
| Area code added in the second six months of a subscription | $41 | $43 |
| Maximum a year, every area code nationwide | $22,626 | $23,425 |
Exempt organizations, such as some charities and political callers, can get the entire registry at no charge. The FTC reviews the fees every fiscal year against inflation, so check the current schedule before you budget.
A number that circulates on Reddit and in Facebook lead-gen groups is "$80 per zip code" -- close on the dollar figure, wrong on the unit. It's per area code. The distinction matters: a single area code typically covers dozens of zip codes, so the real cost of covering a metro area is a fraction of what the zip-code version implies. For an operator calling one or two states, five free area codes plus a handful of paid ones is often enough; national coverage is where the fee adds up.
The obligation runs 31 days, not once
A SAN is a subscription, not a one-time purchase, because the requirement behind it is ongoing: sellers must re-scrub against the registry at least every 31 days. Budget the SAN as a recurring line item, not a setup cost.
Why registry-first vendors default to a sales call
DNC.com and TCPA Litigator List both structure onboarding around the SAN, and it isn't arbitrary -- their core product performs the registry lookup on your behalf, which the FTC's rule says can only happen under your own credential. Asking for it up front is a legitimate consequence of what they sell. The side effect is that a one-person operation with 500 numbers to check gets routed into a subscription conversation before ever seeing a price, purely because the registry check is bundled with everything else.
A tool whose primary checks are carrier validation and litigator screening doesn't have that constraint, because neither check touches registry data. That's the whole reason NumberBroom can run both from a list upload with no account, no SAN, and no subscription. The registry check is the one part that needs a SAN, so it is opt-in rather than a gate: sign in and link your own, and a paid scrub adds it, free on lists of up to 1,000 numbers.
What to actually do
- Get your own SAN at donotcall.gov if you don't have one, and use it to pull registry data for the area codes you call into.
- Run your registry scrub against that data yourself, or share your SAN with a vendor that runs it for you if you'd rather not manage downloads on a 31-day cycle. NumberBroom does this on a signed-in paid scrub once your SAN is linked, for lists of up to 1,000 numbers; larger lists and state lists are still yours to scrub.
- Run carrier validation and a litigator scrub as well -- no SAN required, and the two checks that actually determine whether a number is worth dialing in the first place.
Treating these as one bundled decision is what stalls people. They're two different data sources with two different access rules, and only one of them needs a federal credential to touch.
Check a single number with the free carrier lookup, or see bulk pricing.
Frequently asked questions
How much does a SAN cost?
The first five area codes are free, and beyond that the FTC charges per area code, per year. Until 30 September 2026 the fee is $82 per area code, with a maximum of $22,626 a year for every area code nationwide. From 1 October 2026 it rises to $85 per area code, with a maximum of $23,425; the first five stay free. An area code added in the second six months of a subscription year costs half: $41 until 30 September 2026, $43 from 1 October 2026. The FTC reviews the fees every fiscal year, which starts on 1 October, so re-check the current schedule before budgeting.
A common misreading calls this "$80 per zip code." It is per area code, not zip code -- area codes cover far more ground, so the real cost of national coverage is lower than the zip-code version suggests, though still real money for a small operator calling across many regions.
Who has to hold the SAN -- me, or my vendor?
You, if you are the seller whose goods or services are being marketed. The FTC is explicit that a telemarketer or scrubbing vendor working on your behalf operates under your SAN, shared with them -- not their own. This is why DNC.com and TCPA Litigator List both ask a new customer to provide a SAN before they'll run a registry check: they are performing the lookup for you, under your credential, not selling you access to a registry they hold.
Can NumberBroom scrub my list without a SAN?
For carrier validation and the litigator check, yes -- neither draws on registry data, so there's nothing to gate. For the federal Do Not Call Registry specifically, no tool can legally scrub on your behalf without your SAN; that is an FTC access rule, not a product limitation. Get your own SAN at donotcall.gov and link it in NumberBroom's Settings: once we confirm it with the FTC, a signed-in paid scrub includes a federal Do Not Call Registry check under it, free on lists of up to 1,000 numbers. State lists, your internal list and the 31-day schedule stay yours.
Why do some scrubbing vendors require a SAN before I can even sign up?
Because their core product is a DNC registry lookup, and that check cannot run without one. If a vendor's onboarding starts by asking for your SAN, their scrub is registry-only, or they bundle the registry check with other services and need the credential up front for all of them. A vendor whose scrub is carrier validation and litigator screening -- data sources that don't touch the registry -- has no reason to ask for a SAN at all.
- FTC -- 2027 Telemarketer Fees to Access the National Do Not Call Registry (26 August 2026)
- Federal Register -- Telemarketing Sales Rule Fees (91 FR 54947, effective 1 October 2026)
- FTC -- Telemarketer Fees to Access the National Do Not Call Registry to Increase in 2026
- FTC -- Q&A for Telemarketers & Sellers About DNC Provisions in the TSR
- National Do Not Call Registry (donotcall.gov)