How Often Must Businesses Scrub Call Lists Against the National Do Not Call Registry?

Sellers and telemarketers must check their call lists against the National Do Not Call Registry and purge any matching numbers at least once every 31 days. The FTC set this requirement by amending the Telemarketing Sales Rule, and it has applied continuously since it took effect on January 1, 2005.

Why 31 Days Instead of a Round Number

The FTC's rulemaking moved telemarketers from quarterly Registry checks to monthly ones, following a directive in the Consolidated Appropriations Act of 2004. When finalizing the rule, the Commission set the interval at 31 days rather than 30 specifically to give sellers and telemarketers the maximum amount of time allowable under the law for a monthly scrubbing cycle. The regulatory text requires that any version of the Registry used to scrub a list be no more than 31 days old at the time a call is placed.

The Established Business Relationship Exception

The Telemarketing Sales Rule has long allowed calls to registered numbers under a separate exception for an established business relationship — generally up to 18 months after a consumer's last purchase, payment, or delivery, or up to three months after a consumer's inquiry or application to the company. This exception runs independently of the 31-day scrub requirement: it doesn't excuse a business from scrubbing its list, it just permits calls to specific numbers that would otherwise be blocked by Registry membership.

A Company-Specific Do Not Call Request Overrides Everything

Separate from the national Registry, if an individual consumer directly asks a specific company not to call them again, that company must record the request and honor it going forward — even in situations where an established business relationship would otherwise permit a call. This internal do-not-call obligation doesn't expire the way the 18-month relationship exception does.

This Is a Compliance Floor, Not a Suggestion

Violating the Telemarketing Sales Rule's Do Not Call provisions carries real civil penalty exposure per violation, and "we didn't realize our list was out of date" isn't a defense the rule accommodates — the 31-day ceiling is the maximum age a scrub can be, not a recommended cadence. One 2026 compliance guide puts potential per-call civil penalty exposure as high as $53,088, though that figure should be checked against the FTC's current penalty schedule rather than treated as a fixed amount, since civil penalty caps under the rule are adjusted periodically for inflation.

Registry Access Itself Has a Yearly Fee

Businesses don't get free, unlimited access to the Registry. The FTC charges telemarketers to access the list by area code, and it raises that fee most years — for fiscal year 2026, the agency set the cost at $82 per area code, up $2 from fiscal year 2025, with an annual cap of $22,626 for access to every area code nationwide. That fee structure is a separate, additional cost from any penalty exposure tied to failing to scrub on time.

Bottom Line

Automate your Registry sync on a calendar no looser than every 31 days, track company-specific opt-out requests in a system that never expires them, and don't rely on the established business relationship exception as a substitute for keeping your list itself current.

Sources: FTC, "Telemarketers Required to Scrub Their Call Lists Every 31 Days Beginning January 1, 2005" (search.ftc.gov press release); FTC, National Do Not Call Registry FAQs for business.