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's fee schedule for fiscal year 2026, effective 1 October 2025:
- First 5 area codes: free.
- Each additional area code: $82/year, or $41 for a half-year subscription.
- Maximum annual charge, all area codes nationwide: $22,626.
- Exempt organizations (charities, political groups) can access the full registry at no charge.
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 CSV upload with no account, no SAN, and no subscription — the check that would require one isn't part of the product.
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 registry-focused vendor if you'd rather not manage downloads on a 31-day cycle.
- Run carrier validation and a litigator scrub separately — 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 free, or see bulk pricing.
Frequently asked questions
How much does a SAN cost?
The first five area codes are free. Beyond that, the FTC charges $82 per area code per year (or $41 for a half-year) as of FY2026, effective 1 October 2025 — up $2 from the prior year. Fees are set annually, so re-check the current schedule before budgeting. The maximum any single entity can be charged for every area code nationwide is $22,626 a year.
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 run that check under it, the way the rule requires.
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.