DNC list for businesses: registry access, scrubbing and state lists
The DNC list for businesses is the National Do Not Call Registry, which sellers and telemarketers must check before sales calls. Under FTC and FCC rules, a business subscribes for the area codes it calls, removes registered numbers at least every 31 days, keeps its own do-not-call list and checks state lists that apply.
This page reflects 16 CFR Part 310 and 47 CFR 64.1200 as shown in the Electronic Code of Federal Regulations, and FTC and FCC guidance, checked on October 6, 2026. It is general information for businesses, not legal advice. If you want to stop sales calls to your own number, register at donotcall.gov.
Key points
- Both the FTC (16 CFR 310.4) and the FCC (47 CFR 64.1200(c)) bar sales calls to numbers on the National Do Not Call Registry unless an exemption applies.
- Each seller needs its own registry subscription; data for the first five area codes is free and fees apply after that.
- Call lists must be checked against a version of the registry obtained no more than 31 days before the call.
- Businesses must also keep an internal do-not-call list and honor requests within ten business days under the FCC rule.
- Some states run their own do-not-call lists, and the TSR does not preempt state law.
The DNC list for businesses: what are the rules?
The DNC list rules come from two federal agencies that enforce one National Do Not Call Registry, each under its own rule:
- FTC: under the Telemarketing Sales Rule, 16 CFR 310.4(b)(1)(iii)(B), a seller or telemarketer may not make an outbound sales call to a number on the registry unless it can show the person’s express written agreement to calls from a specific party, or an established business relationship.
- FCC: under 47 CFR 64.1200(c)(2), no person may make a telephone solicitation to a residential subscriber who has registered on the national registry. Registrations must be honored indefinitely, or until the consumer cancels or the number is removed. Under 64.1200(e), these rules also apply to calls and texts to wireless numbers.
The FCC rule also sets calling hours: no telephone solicitations to residential subscribers before 8 a.m. or after 9 p.m. local time at the called party’s location (64.1200(c)(1)).
Your own do-not-call list
The registry is only one list. Businesses must also keep an entity-specific list of people who asked that business not to call. Under 64.1200(d), a business that makes telemarketing calls needs a written do-not-call policy available on demand, trained staff, and a process to record requests. Requests must be honored within a reasonable time, not more than ten business days, and kept for 5 years. The TSR has a matching ban on calling a person who asked a seller not to call (310.4(b)(1)(iii)(A)).
How businesses get access to the National Do Not Call Registry
Access is through the FTC’s telemarketer site at telemarketing.donotcall.gov. Access is limited to sellers, telemarketers and other service providers. The steps, based on the FTC’s Q&A for telemarketers and sellers:
Create a profile
Give your company name and address and a contact person. A telemarketer working for clients also identifies each seller-client.
Choose area codes
Select the area codes you will call. You can select every area code in a state, or the whole registry.
Pay any fee
Data for the first five area codes is free. Fees apply per area code after that, up to an annual maximum (see the next section).
Get a Subscription Account Number (SAN)
Each seller must have its own subscription and SAN. A telemarketer may access data for a seller using that seller’s SAN, and may use that data only for that seller.
Download and refresh
Download the numbers for your area codes. Data files may be downloaded once in any 24-hour period, and change-only files are available after the first download.
Registry fees
The fee is set in 16 CFR 310.8(c). The text in effect from October 1, 2026 sets $85 for each area code of data after the first five, up to a maximum of $23,425 a year. The FTC adjusts the fees each fiscal year, so check the current rule before you subscribe. The same paragraph bars any arrangement to share the cost of registry access, including dividing it among a telemarketer’s clients. Organizations that may access the registry but are not required to (for example, some exempt organizations) are not charged.
What is a DNC list check (scrubbing)?
A DNC list check, often called scrubbing, compares the numbers you plan to call with the registry and your other suppression lists, and removes any number you may not call. Both agencies’ safe harbors require it to be done against a version of the registry obtained no more than 31 days before the call (16 CFR 310.4(b)(3)(iv); 47 CFR 64.1200(c)(2)(i)(D)).
A DNC list scrubber is any software or service that runs this comparison. Some businesses build it into their dialer or CRM; others send lists to a provider. Whatever tool you use, the rules are the same: you need your own registry subscription, the data may be used only for compliance, and you must keep records showing the process.
How to scrub a call list
- Download the current registry data for your area codes, at least every 31 days.
- Load the state do-not-call lists for the states you call, where those states run lists.
- Load your internal do-not-call list and your record of consent revocations.
- Remove every match unless you have a documented exemption for that number, such as the person’s signed written agreement or an established business relationship.
- Re-check numbers that were scrubbed more than 31 days ago before calling them again.
- Save a record of each scrub: the registry version date, the lists used and the numbers removed.
State DNC lists
Some states administer their own do-not-call registries. The FTC’s guidance states that the TSR does not preempt state law, so sellers and telemarketers have to check with each state to see what is required. State lists can have their own registration, fee, scrubbing and exemption rules, and state telemarketing laws can add calling-hour or consent rules on top of the federal ones.
To find what applies, check the attorney general or consumer protection office of each state you call into. How state laws layer on the federal rules is covered in state TCPA laws.
Exemptions from the DNC list rules
The exemptions are narrow and differ between the two rules. A call may be exempt under one rule and still covered by the other.
| Exemption | FCC (47 CFR 64.1200) | FTC (16 CFR Part 310) |
|---|---|---|
| Written agreement from the person | Prior express invitation or permission, shown by a signed written agreement that the consumer agrees to be contacted by this seller, with the number ((c)(2)(ii)) | Express agreement in writing authorizing calls by or on behalf of a specific party, with number and signature (310.4(b)(1)(iii)(B)(1)) |
| Established business relationship | Purchase or transaction within 18 months, or inquiry or application within 3 months ((f)(5)) | Purchase within 540 days, or inquiry or application within 90 days (310.2) |
| Ended by a do-not-call request | Yes: a seller-specific request ends the relationship for telemarketing ((f)(5)(i)) | Yes: the exemption does not apply if the person asked not to be called |
| Personal relationship | Calls by a telemarketer to family, friends or acquaintances ((c)(2)(iii)) | Not listed as a registry exemption |
| Nonprofits and charities | Calls by or on behalf of tax-exempt nonprofits are not telephone solicitations ((f)(15)) | Charitable solicitations are not covered by the registry provision (310.6(a)) |
| Business-to-business calls | Rule addresses residential subscribers | Most calls to businesses are exempt (310.6(b)(7)) |
The FTC’s guidance also lists calls from political organizations and pure telephone surveys as outside the registry provisions. The FCC’s consumer guide describes the registry as a list of landline and wireless numbers that legitimate telemarketers agree not to call.
How DNC rules apply to lead generation
When a person submits a lead form and a buyer calls them, the buyer is the business making the sales call, so the Do Not Call duties sit with the buyer and anyone calling on its behalf. Consent captured on the form is what a buyer relies on for a registered number, which is why the consent has to clearly authorize that buyer and include the number. See express written consent.
Sellers and publishers have their own part: they should not send a lead for a number that has opted out, and they should pass revocations to buyers. Summit Leads captures TCPA consent on every lead and delivers consent certificates, which buyers use alongside their own scrubbing. The full lead lifecycle is explained in the lead generation industry guide, and the buyer side on the for buyers page.
Buying MVA or home improvement leads? Every Summit lead carries a consent certificate.
Common mistakes
- Scrubbing once and calling for months. The safe harbors require a registry version no more than 31 days old at the time of the call.
- Borrowing another company’s subscription. Each seller needs its own subscription, and cost-sharing is barred.
- Forgetting the internal list. A person who asked you not to call must not be called, even if their number is not on the registry.
- Ignoring state lists. Federal compliance does not cover state registries.
- Treating an old inquiry as a relationship. The inquiry window is 3 months under the FCC rule and 90 days under the TSR.
For publishers
Sending traffic to Summit landers? Read the publisher traffic guidelines and TCPA basics for lead gen affiliates. For how the wider industry works, see the lead generation industry guide.
Frequently asked questions
How do businesses access the Do Not Call list?
Through the FTC’s telemarketer site, telemarketing.donotcall.gov. You create a profile, choose area codes, pay any fee due and receive a Subscription Account Number.
How often do you have to scrub against the DNC list?
At least every 31 days. Both the FTC and FCC safe harbors refer to a registry version obtained no more than 31 days before the call.
Do DNC rules apply to cell phones?
Yes. Consumers may register wireless numbers, and 47 CFR 64.1200(e) applies the FCC’s Do Not Call rules to calls and texts to wireless numbers.
Can a lead buyer call a number on the DNC list?
Only if an exemption applies, such as the person’s signed written agreement to be called by that seller or an established business relationship that has not been ended by a do-not-call request. Check with counsel.
Is this legal advice?
No. This page is general information about the federal rules. Talk to a lawyer about your own calling program.
Related guides
- TCPA compliance hub: Every TCPA guide on the site.
- DNC list violations: What counts as a violation and the penalties.
- Telemarketing Sales Rule: The FTC rule behind the registry.
- State TCPA laws: State rules on top of the federal ones.
- TCPA for ping/post delivery: Consent and delivery in real-time lead sales.
Sources
- 16 CFR Part 310, Telemarketing Sales Rule, Electronic Code of Federal Regulations
- 47 CFR 64.1200, Delivery restrictions, Electronic Code of Federal Regulations
- Q&A for Telemarketers & Sellers About DNC Provisions in TSR, Federal Trade Commission
- Complying with the Telemarketing Sales Rule, Federal Trade Commission
- Stop Unwanted Robocalls and Texts, Federal Communications Commission
- National Do Not Call Registry for telemarketers, Federal Trade Commission
- National Do Not Call Registry, Federal Trade Commission
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