The National Do Not Call Registry is administered by the FTC under the Telemarketing Sales Rule. Access is credentialed, and the credential is the SAN.
Who needs one
- Sellers — any business whose goods or services are being marketed by phone. You need your own subscription and your own SAN.
- Telemarketers and service providers — you operate under the SAN of each seller you work for, shared with you by that seller.
- Exempt organisations — may still need access to honour the registry voluntarily or to satisfy state rules.
The seller-owns-the-SAN structure exists so that liability tracks to the party benefiting from the calls. Delegating the work does not delegate the obligation.
Track your providers' downloads
Because the 31-day requirement runs against you, you need to know when each provider you shared your SAN with last pulled registry data. The FTC recommends exactly this: knowing the date of the last download tells you whether the requirement is actually being met on your behalf.
If you have shared your SAN with three vendors and none of them can tell you their last download date, you have a compliance gap regardless of how diligent each of them believes they are.
What a DNC scrub does not cover
This is the important part, and it is where callers most often assume more protection than they have. A registry scrub tells you one thing: whether the consumer asked the federal registry to stop marketing calls. It tells you nothing about:
- Line type — whether the number is a live mobile, a landline, or disconnected. More
- Known litigators — who typically stay off the registry deliberately, because being called is the point. More
- Reassignment — whether the number still belongs to the person who consented. More
- State registries — several states maintain their own, some with stricter rules.
- Your internal do-not-call list — a separate obligation with no exemptions.
DNC-only is the most common gap
Teams that scrub against the registry and stop there often believe they are covered. The registry is one of five checks. NumberBroom handles carrier validation, line type and the litigator check in one pass at $0.044 per row; the registry scrub itself you run under your own SAN. How the checks fit together.
Frequently asked questions
Can my telemarketer use their own SAN for my calls?
No. The FTC is explicit that every seller must have its own subscription and SAN, separate from the telemarketer's. If you engage a telemarketer or service provider to buy a list, scrub a list, or make calls on your behalf, you share your SAN with them — you do not use theirs.
How often must I scrub against the registry?
At least every 31 days. The FTC tightened this from quarterly effective 1 January 2005. Treat 31 days as a ceiling, not a target — scrubbing immediately before each campaign is the practical standard.
Is the Do Not Call Registry free for businesses?
Access to a limited number of area codes is free; broader access is paid, priced by the number of area codes you subscribe to. Exempt organisations can obtain access at no charge. Current fee schedules are on the FTC's telemarketing registry site.
Do consumer registrations expire?
No. A consumer's number stays on the registry indefinitely. The FTC removes it only if the number is disconnected and reassigned, or if the consumer asks for removal. The old belief that registrations lapse after five years has not been true for many years.