03Compliance
National Do Not Call Registry for businesses: who subscribes, what it costs, how often to scrub
Any seller or telemarketer that calls consumers must download the registry for each area code it dials and refresh it at least every 31 days. This page covers the fees, the exemptions, the state lists and the penalty.
AShort answer
Sellers and telemarketers that call consumers must access the National Do Not Call Registry and use a version no more than 31 days old. Under the FY2027 fee schedule, effective 10/01/2026, the first five area codes are free, each additional area code costs $85 per year, and total annual charges cap at $23,425. Business-to-business calls are mostly exempt.
| Who must subscribe | Sellers, telemarketers and their service providers that call consumers |
|---|---|
| Scrub window | Registry version no more than 31 days old on the day of each call |
| Free area codes | First 5 area codes |
| Fee after 5 (FY2027) | $85 per area code per year, from 10/01/2026 |
| Annual fee cap (FY2027) | $23,425 for all area codes |
| Established business relationship | 18 months after a purchase, 3 months after an inquiry |
| Civil penalty | Up to $53,088 per violation, each call can count separately |
Who has to subscribe
A seller or a telemarketer that makes outbound calls to consumers must subscribe to the registry. The Telemarketing Sales Rule (TSR), the FTC rule at 16 CFR Part 310, defines a seller as a person who provides goods or services for consideration in a telemarketing transaction. It defines a telemarketer as a person who initiates or receives calls to or from a customer (16 CFR 310.2). Access is limited to sellers, telemarketers and their service providers.
The seller carries the duty even when an outside call center dials. The seller must hold its own subscription and Subscription Account Number (SAN), separate from the telemarketer's. The telemarketer must confirm that its seller clients have paid before it calls for them. A real estate team that outsources dialing still needs its own account.
Open the account at telemarketing.donotcall.gov. You list the area codes you plan to call, download the data for them, and your SAN expires when your subscription does. For the wider rules on cold calls, read cold calling laws by state. The family index is the compliance hub.
The 31-day scrub rule
To scrub means to remove registry numbers from your call list before dialing. The FTC says you must synchronize your lists with an updated version of the registry at least every 31 days. The rule text, 16 CFR 310.4(b)(3)(iv), requires a registry version obtained "no more than thirty-one (31) days prior to the date any call is made."
The 31 days run from the day you download, not the day you upload to a dialer. A list scrubbed on day 1 and dialed on day 40 is out of compliance for those calls. Scrub again right before a large campaign, and re-run purchased or appended lists every time they enter your system.
The safe harbor in 310.4(b)(3) protects a caller who proves it follows a written process, trains staff, keeps a company-specific list, uses the registry no more than 31 days before calling, keeps records, and monitors and enforces compliance. One mistaken call then does not create liability. Without those records you lose the defense.
What the registry costs in FY2027
The FTC announced the FY2027 fees on 08/26/2026. They take effect 10/01/2026.
| Item | FY2027 amount |
|---|---|
| First five area codes | Free |
| Each additional area code, per year | $85 (up $3 from FY2026) |
| Maximum charge for all area codes nationwide | $23,425 (up from $22,626) |
Worked example. A brokerage that calls 12 area codes pays for 12 minus 5 free, which is 7 paid codes. 7 x $85 = $595 per year. A regional team calling 40 area codes pays 35 x $85 = $2,975. The cap binds at the 276th paid area code, because 275 x $85 = $23,375 and 276 x $85 = $23,460.
Fees do not buy permission to call. They buy the data. Use the homeowner counts to see which markets sit in which area codes before you subscribe.
Exemptions and the company-specific list
Registry rules have exceptions. None of them lifts the duty to honor a company-specific request.
| Exemption | Rule | Cite |
|---|---|---|
| Established business relationship (EBR) after a purchase | 18 months from the purchase, lease or transaction (the rule counts 540 days) | 16 CFR 310.2(q); FTC Q&A Q10 |
| EBR after an inquiry or application | 3 months from the inquiry (the rule counts 90 days) | 16 CFR 310.2(q) |
| Express written agreement | The person agreed in writing to be called, and you can prove it | 16 CFR 310.4(b)(1)(iii)(B)(1) |
| Business-to-business calls | Calls to a business to sell goods or services to that business | 16 CFR 310.6(b)(7) |
The B2B exemption has limits. The misrepresentation bans in 16 CFR 310.3(a)(2) and (4) still apply to business calls. A call to an owner's personal mobile about a consumer offer is not a B2B call.
The company-specific list works differently. If a person tells you not to call, you must put the number on your own list and stop calling, even when an EBR exists (16 CFR 310.4(b)(1)(iii)(A)). The FTC says a seller can rely on an EBR only if the consumer has not asked to be on the seller's entity-specific list. Keep that list permanently. For handling requests, see consent revocation rules.
State lists that need a separate purchase
The national registry does not replace every state list. Three states below publish their own list for telemarketers. Each fact comes from the state's own page or rule.
| State | What the caller buys | Cost and cadence | Source |
|---|---|---|---|
| Indiana | Indiana Do Not Call list, plus separate telephone solicitor registration | $750 per year for four quarterly lists | Indiana Attorney General |
| Pennsylvania | PA Do Not Call list, required of all telemarketers even if exempt from registration | $495 per year, quarterly updates, remove numbers within 30 days of each list | Pennsylvania Attorney General |
| Texas | Texas No-Call List, which includes the Texas portion of the national registry | Fee capped at $75 per list per quarter, published January 1, April 1, July 1 and October 1 | 16 Tex. Admin. Code 26.37 |
Pennsylvania also requires registration for most telemarketers: a $500 fee, a $50,000 surety bond or equivalent, and renewal every two years. Check each state agency before your first call there, because fees and rules change. States not named here are not cleared by this table.
Scrub cadence and record keeping
| Task | Minimum cadence | Record to keep | Cite |
|---|---|---|---|
| National registry download | At least every 31 days, before the calls | Registry version used, access date, SAN, campaign | 310.4(b)(3)(iv); 310.5(a)(11) |
| Company-specific list | Update on every request | Name, number, date, seller, goods or service | 310.4(b)(1)(iii)(A); 310.5(a)(10) |
| EBR claims | Check the 18-month or 3-month window before each call | Name, number, inquiry date, product | 310.5(a)(5) |
| Written agreements | At collection | Consent copy, date, name, number | 310.5(a)(8) |
| Call records | Every call | Numbers, date, time, duration, script, disposition | 310.5(a)(2) |
| State lists | Each quarterly issue | Version, date, state | State rules above |
The general retention period under 310.5(a) is 5 years from the date the record is produced, with some records measured from the end of use or contract expiry.
What changed in the last 24 months
- 08/26/2026: The FTC announced FY2027 fees effective 10/01/2026. The per-area-code price rose $3 to $85, and the cap rose from $22,626 to $23,425.
- 09/15/2026: The FTC published a notice that its civil penalty amounts stay unchanged during 2026 and that it keeps applying the 2025 levels, because the government shutdown prevented the data the inflation adjustment needs.
- 01/17/2025: The last inflation adjustment to FTC civil penalties took effect (90 FR 5581), which sets the $53,088 figure now in force.
The single policy that clears all of it
- Open your own SAN at telemarketing.donotcall.gov and download every area code you dial.
- Scrub within 31 days before each call, and re-scrub new lists on the day they arrive.
- Buy and scrub the Indiana, Pennsylvania and Texas lists before calling those states.
- Treat every mobile as a consumer number. Call a business line only for a business sale.
- Call on an EBR only inside 18 months of a purchase or 3 months of an inquiry, and log the date.
- Store written agreements with the date and the number.
- Add any do-not-call request to your company list the same day, and keep it permanently.
- Keep records for 5 years.
This policy sits on top of the autodialer and text rules in the TCPA explained, which can be stricter than the registry rules.
Penalty exposure
The FTC says violators may face fines of up to $53,088 per violation, and each call may be a separate violation. The figure is the 2025 adjustment in 16 CFR 1.98. The FTC confirmed on 09/15/2026 that it applies the 2025 levels during 2026. A dialer that makes 1,000 registry calls costs up to 1,000 x $53,088 = $53,088,000 on paper. State attorneys general add their own penalties, and consumers have private claims under the TCPA. See telemarketing penalties for the full range, and the cold calling playbook for dialing practice. Homeowner prospect data is described in the homeowner list guide.
Next step
Get counts for the markets you plan to dial, then match them to area codes before you subscribe. Start at get counts.
This page is a plain-English summary with sources, not legal advice. Last reviewed 10/10/2026.
Questions people ask
Q01Do I need to pay if I only call five area codes?
No. Data for up to five area codes is free. You still need a subscription account at telemarketing.donotcall.gov and a Subscription Account Number, and you still have to refresh the data at least every 31 days.
Q02Can I call a number on the registry if the person filled out my web form?
Only with an established business relationship or express written agreement to be called. An inquiry gives you three months. A signed agreement that names your company and the number has no time limit, but a company-specific do-not-call request ends it.
Q03Does the registry cover business phone numbers?
The registry is for consumers. Most calls to a business to sell to that business are exempt. A mobile number belongs to a person, so treat it as a consumer number unless you can show the call is a genuine business-to-business sale.
Q04If a telemarketer dials for me, who pays?
Both. The seller must hold its own subscription and Subscription Account Number, separate from the telemarketer's. The telemarketer must confirm the seller has paid before it calls on the seller's behalf.
Q05Does a state list replace the national registry?
No. Some states, including Indiana, Pennsylvania and Texas, require telemarketers to buy a state list as well. You scrub against the national registry and each state list that applies to the area you call.
Sources
- FTC press release, 2027 telemarketer fees for the National Do Not Call Registry (08/26/2026)ftc.gov
- FTC Q&A for telemarketers and sellers about DNC provisions in the TSRftc.gov
- 16 CFR 310.4 Abusive telemarketing acts or practiceslaw.cornell.edu
- 16 CFR 310.2 Definitionslaw.cornell.edu
- 16 CFR 310.5 Recordkeeping requirementslaw.cornell.edu
- 16 CFR 310.6 Exemptionslaw.cornell.edu
- 16 CFR 1.98 Adjustment of civil monetary penalty amountslaw.cornell.edu
- FTC notice, civil penalty inflation adjustments unchanged for 2026 (Federal Register, 09/15/2026)public-inspection.federalregister.gov
- National Do Not Call Registry, telemarketer access sitetelemarketing.donotcall.gov
- Indiana Attorney General, Do Not Call list for telephone solicitorsin.gov
- Pennsylvania Attorney General, Telemarketing FAQattorneygeneral.gov
- 16 Tex. Admin. Code 26.37, Texas No-Call Listlaw.cornell.edu
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