How to Scrub a Call List Against the National Do Not Call Registry

To scrub a calling list against the National Do Not Call Registry, register as a seller at the FTC's telemarketer access site, get a subscription account number (SAN), and download the Registry numbers for every area code on your list. Remove matches from the list, apply your own company-specific do-not-call list and any documented exemptions, and record the date and version you used. Repeat at least every 31 days. Clean and normalise the list first, so every number matches in one format.

This guide walks through each step, what access costs, who is exempt, and where phone validation fits. It is a practical guide, not legal advice. For anything that affects your exposure, talk to counsel.

Who has to scrub

The FTC's Telemarketing Sales Rule guidance applies Registry requirements to sellers and telemarketers making sales calls to consumers. The FCC has parallel rules under the TCPA. Its rule at 47 CFR 64.1200 protects residential subscribers who registered their number, and section (e) applies the do-not-call rules to wireless numbers.

Three exemptions come up most often. All three need records you can produce.

Exemption	What the FTC guidance says	What to keep
Business-to-business calls	The Registry prohibition "does not apply to business-to-business calls", except calls selling nondurable office or cleaning supplies and calls soliciting sales or donations from employees	Evidence the number is a business line and the call targets the business
Established business relationship	18 months from the last purchase, payment or shipment; 3 months from an inquiry or application. Live calls only, not robocalls	Transaction or inquiry date per contact
Written permission	Must be in writing, include the number that may be called, and carry the consumer's signature, which can be electronic. Pre-checked boxes do not count	The signed agreement

The B2B exemption is narrower in practice than it sounds. A business list often contains owners' personal mobiles, and you cannot tell a business line from a personal one by looking at the number. Many teams scrub every number and treat the exemption as a backstop, not a plan.

What access costs

Per the FTC's guidance, checked on 13 October 2026:

• The first five area codes are at no charge.
• Each additional area code costs $85 a year.
• Access to every area code costs $23,425 a year, whichever is less.
• Area codes added in the second half of the subscription year cost $43 each.
• Fees cannot be shared between sellers.

Each seller gets its own SAN, which it can share with telemarketers and service providers that call on its behalf. A telemarketer that accesses the Registry for itself gets a separate SAN, which the FTC says is not transferable.

Step 1: Clean the list before you scrub

A scrub is a match on the phone number. If the same number is stored as (212) 555-0147, 212.555.0147 and +1 212 555 0147, a naive match can miss two of them. Clean first:

1. Normalise every number to one format. E.164 (+12125550147) is safest, then strip to the 10-digit national number for the match. Our US phone number format guide covers the rules.
2. Validate against the numbering plan. Remove numbers that cannot exist, such as wrong length or invalid area codes, and fictional 555-01XX numbers. See 555 numbers.
3. Deduplicate after normalising. Our guide to removing duplicate phone numbers shows how.
4. List the area codes that remain. This tells you which Registry area codes you need to buy.

Validation also cuts wasted dials. Our phone validation for cold calling guide covers the rest of the pre-dial checks.

Step 2: Register and choose area codes

Create a seller account on telemarketing.donotcall.gov, pay for any area codes beyond the first five, and note your SAN. If an agency or call center dials for you, give them your SAN so they can download under your subscription. Do not borrow theirs.

Worked example: what a list costs to scrub (illustrative)

The list below is made up to show the arithmetic.

Step	Rows	Note
Raw list from three sources	18,400	Mixed formats
After normalising and removing invalid numbers	17,650	750 failed the numbering plan
After deduplication	15,900	1,750 duplicates across sources
Distinct area codes	12	Mostly one metro region

Cost of access for the year: 5 area codes at no charge, plus 7 × $85 = $595. If the list had spanned 300 area codes, the fee would hit the $23,425 cap instead of 295 × $85 = $25,075.

Step 3: Download and match

Download the Registry numbers for your area codes and match them against the cleaned list on the 10-digit number. Mark each match as do not call rather than deleting it. You want a record that the number was suppressed, and you do not want a later import to bring it back.

Save three things with every scrub:

• The date and time of the download.
• The area codes covered.
• The count of numbers matched and suppressed.

Step 4: Apply your own do-not-call list

The Registry is not the only list. Every seller must keep an entity-specific do-not-call list of people who asked your company not to call them. The FTC says sellers and telemarketers may not refuse such a request. The FCC's rule at 64.1200(d) adds two time limits:

• Honor a request within a reasonable time, which "may not exceed ten (10) business days" from receipt.
• Honor it "for 5 years from the time the request is made."

Apply this list after the Registry scrub, on every list, every time. It also limits the established-business-relationship exemption. The FTC guidance allows those calls only if "the consumer has not asked to be on the seller's entity-specific Do Not Call list."

Step 5: Apply exemptions only with evidence

If you rely on an established business relationship or written permission, re-add those numbers only when you hold the record for that contact and it is still in date. An inquiry from five months ago is outside the three-month window. A purchase from two years ago is outside the 18-month window.

Step 6: Repeat every 31 days and block at the dialer

The FTC guidance says to remove Registry numbers from call lists "at least every 31 days". The FCC's safe harbor refers to a Registry version obtained "no more than 31 days prior to the date any call is made". Put the next scrub date on a calendar, and block suppressed numbers in the dialer itself, not just the spreadsheet.

The safe harbor checklist

The FTC lists the elements of the safe harbor for a call made in error:

• Written procedures for honoring do-not-call requests.
• Training for staff and anyone helping with compliance.
• A maintained entity-specific do-not-call list.
• A process, with records, that uses a Registry version downloaded within 31 days.
• Monitoring and enforcement of those procedures.
• The call was a result of error.

Each step above produces one of these records.

What happens if you skip it

The FTC's guidance lists civil penalties of up to $53,088 per violation for Registry and entity-specific violations. Under the TCPA, 47 U.S.C. 227(c)(5) gives a person who received more than one solicitation within 12 months in violation of the FCC rules a private right of action, with damages of up to $500 per violation, up to three times that if the violation was willful or knowing. The same section provides a defense for a caller that implemented reasonable practices and procedures with due care.

Other rules that sit beside the scrub

A scrubbed list is not a compliant campaign by itself. Two more rules from the FTC guidance apply to every call:

• Calling hours. Unless the consumer agreed otherwise, calls to a home are limited to 8 a.m. to 9 p.m. local time at the called location. Add the time zone to each row before dialing.
• Caller ID. Telemarketers must transmit their number and, where available, their name.

Line type matters too. The TCPA treats calls and texts to mobiles differently from calls to landlines. Our guide to TCPA mobile vs landline rules explains the difference, and the Reassigned Numbers Database helps when your consent is old.

Common scrubbing mistakes

Most scrubbing failures are process failures, not data failures. These are the ones to design out:

Mistake	Why it fails	Fix
Matching raw numbers in mixed formats	(212) 555-0147 does not equal 2125550147 in a plain text match	Normalise before matching
Scrubbing once at import	A number registered after your scrub is protected once the 31-day window passes	Re-scrub every list at least every 31 days
Deleting matches instead of flagging them	A later import of the same source brings the numbers back	Keep a suppression table and apply it on every import
Using a vendor's or agency's SAN	Fees cannot be shared between sellers, and the SAN identifies who has access	Each seller holds its own subscription
Scrubbing the spreadsheet, not the dialer	Reps dial from a different, older copy of the list	Block suppressed numbers in the dialer
Treating every list as B2B	Business lists contain personal mobiles	Scrub everything unless you can prove the exemption
Losing the paper trail	The safe harbor depends on written procedures and records	Store the download date, area codes and match counts per scrub

A short written procedure that names who runs the scrub, when, and where the records live covers several safe harbor elements at once.

Where SimpleVerifier fits, and where it doesn't

SimpleVerifier does not scrub against the Do Not Call Registry. The scrub uses Registry data you download under your own SAN.

What it does is the cleaning in Step 1. The phone number validator checks a number against its country's numbering plan and returns it in E.164. In bulk, the Pro plan at $29.99 a month normalises and validates a whole CSV and returns the numbering-plan type. The Email + Phone plan at $49.99 a month adds 5,000 live carrier lookups a month with the real line type (mobile, landline or VoIP) and the carrier name, including US numbers. No lookup can confirm a person is using a number today. See pricing for details, and our call center use case for the full pre-dial workflow.

The short version

Clean the list first: normalise, validate and deduplicate. Register at telemarketing.donotcall.gov, get your SAN, and buy the area codes on your list beyond the first five. Download, match and mark Registry numbers as do not call. Apply your company-specific list, honor new requests within ten business days and keep them for five years. Re-add exempt numbers only with records. Repeat at least every 31 days, block at the dialer, and keep the dates.