The registry is the oldest and best-known piece of US telemarketing compliance, which is exactly why it is misunderstood. Two errors recur: teams assume that scrubbing it makes a campaign lawful, and teams assume that a number absent from it is safe to dial. Neither holds.
How access works
The registry is not a file you download once. Sellers obtain a Subscription Account Number and pull current data through the FTC's telemarketing portal, and the entitlement is tied to the seller rather than to whoever runs the dialler.
That last point catches people. Handing your SAN to an agency or a list vendor does not move the obligation onto them — the rule places the duty on the seller whose goods or services are being offered. If the vendor's scrub is stale, it is your exposure. See DNC SAN for how access is provisioned.
The 31-day clock is a maximum, not a target
Numbers are added to the registry continuously. A list scrubbed on day 1 and dialled on day 30 is technically compliant and still contains a month of new registrations. The rule sets an outer bound; the sensible operating practice is to scrub per campaign.
Two agencies, two rulebooks
Do-not-call obligations sit in two places at once, and they are not identical. The FTC enforces the Telemarketing Sales Rule; the FCC enforces parallel rules under the TCPA. Their coverage overlaps but does not match, and a caller outside one may still be inside the other.
The practical consequence is that "the FTC rule does not cover us" is rarely a complete answer. The TCPA's separate consent requirements for autodialed and prerecorded calls to mobile numbers apply on their own terms, whether or not the number is registered and whether or not the TSR reaches you. See TSR vs TCPA.
What the registry does not tell you
A DNC scrub answers exactly one question: has this person asked not to receive telemarketing calls generally? It is silent on everything else that determines whether a call is worth making or safe to make.
- Whether the number still works. The registry has no view of disconnections or reassignment. A registered number that was disconnected two years ago and reassigned to someone new looks identical to one that was not.
- Whether it is a mobile. Line type is not a registry field, and the TCPA's strictest consent rules attach to mobile numbers. See line type.
- Whether the person sues for a living. This is the sharpest gap. Serial TCPA litigators are frequently not registered, because registering would reduce the calls they receive and the calls are the point. A DNC-only process filters out the people least likely to sue you and leaves in the people most likely to.
- Whether you already have consent. Documented prior express written consent is a separate record you have to keep yourself. See express written consent.
Where NumberBroom fits, and where it does not
To be direct about it: NumberBroom does not sell DNC registry scrubbing. Registry access runs through your own SAN and stays your obligation, and we would rather say that plainly than let a comparison table imply otherwise.
What we do is the half the registry cannot cover — carrier-level validation, line type, disconnection status, and a court-sourced litigator check, in one pass over your CSV at $0.044 per row. Those checks and a DNC scrub are complements, not substitutes, and a team doing only one of them has a visible hole.
Check a single number free, or read what phone number scrubbing covers.
Frequently asked questions
Does Do Not Call registration expire?
No. Registrations were originally set to lapse after five years, but that expiry was removed and numbers now stay on the registry until the owner takes them off or the number is disconnected and reassigned. You do not need to re-register, and any service offering to "renew" your registration for a fee is not doing anything the registry requires.
How often do telemarketers have to scrub the Do Not Call list?
At least every 31 days. A scrub performed 32 days before a campaign does not satisfy the rule, and the burden of showing the timing sits with the seller. In practice most compliant operations scrub immediately before each campaign rather than tracking a rolling window.
Who is exempt from the Do Not Call Registry?
The registry restricts telemarketing to consumers. Calls that are generally outside it include political calls, calls conducting genuine surveys, debt collection, and calls from charities — though a for-profit fundraiser calling on a charity's behalf must still honour a request not to call again.
Business-to-business calls are generally outside the national registry as well. That is a narrower exemption than it sounds: calling a sole proprietor on a personal mobile is not obviously a B2B call, and the TCPA's separate consent rules for mobile numbers still apply regardless.
What is the difference between the national registry and an internal do-not-call list?
The national registry is a government list of consumers who opted out of telemarketing generally. An internal or company-specific do-not-call list is your own record of people who told you to stop calling.
They are separate obligations. Someone who is not on the national registry can still have asked you directly to stop, and honouring that request is required independently. Scrubbing the national list does not discharge it.
Does an existing customer relationship let me call a registered number?
There is an established business relationship exemption, but it is time-limited and narrower than most teams assume: roughly 18 months from the customer's last purchase, payment or transaction, and about 3 months from an inquiry or application. It also evaporates the moment that person asks you not to call.
Treat it as a short grace period attached to a real transaction, not as a standing permission derived from having a record on file.