Telemarketing remains effective. In fact, for many businesses, making calls remains one of the quickest ways to acquire qualified leads and make sales.
However, there is one error that can quickly turn a profitable venture into a legal nightmare – calling numbers that are registered on the Do Not Call (DNC) Registry.
This is where DNC scrubbing becomes relevant.
Whether you are a solo marketer, a lead seller, or run a high-volume call center, it is no longer optional to understand how DNC compliance works – it is imperative.
In this guide, we will walk you through all the details, including how scrubbing works, the actual costs, the legal boundaries, the risks, and the best practices to remain compliant without hampering your operations.
What Is DNC Scrubbing?
DNC scrubbing is the act of ensuring that your calling list is checked against the National Do Not Call Registry and purging numbers that are not legally permitted to be called for telemarketing purposes.
In layman’s terms:
It is a filtering process that ensures you do not call people who have already told you, “Don’t call me.”
If you do not go through this process, every call you make has the potential to result in:
- FTC fines
- TCPA lawsuits
- Steep fines
- Carrier spam blocking
- Reputation damage
As such, DNC scrubbing is not merely a technical requirement but also serves as a legal safeguard.
How the US National Do Not Call Registry Works
The National DNC Registry is administered by the Federal Trade Commission (FTC).
Consumers can:
- Add their mobile or landline number
- Permanently opt out of telemarketing calls
Once added, the number will remain there indefinitely.
Telemarketers must:
- Access the registry
- Compare their call lists
- Remove registered numbers
If you call someone on the list without a valid exception, you may be violating federal law.
How DNC Scrubbing Services Work in Reality
In theory, companies could download the registry by hand and compare numbers themselves.
In reality? Not so much, especially when dealing with large lists.
The typical process involves the following:
- Upload your lead list
- System checks against the registry
- Numbers marked as flagged are removed
- You download a clean list
Advanced systems can also check against:
- State DNC lists
- Internal suppression lists
- Reassigned numbers
- Wireless/mobile numbers
This increases the accuracy of the list.
At What Volume Do You Incur the Liability
Small-scale marketers believe that risk is only possible at a larger scale. This is not correct.
Even one illegal call can lead to a complaint.
However, the risk of complaints is much higher with a larger number of calls.
For instance:
- 500 calls → low risk
- 10,000 calls → moderate risk
- 100,000+ calls → almost certain complaints
The larger the number of people you call, the higher the chances of being complained against.
At a large scale, it is essential to clean every call.
Why the FTC Registry Is Not Built for High-Volume Lead Operations
The FTC system was meant for compliance, not efficiency.
It has some drawbacks such as:
- Download by hand
- Slow processing
- Limitations on file size
- No automation
If you are processing thousands of calls per day, this is impossible to handle.
This is the reason why professional call centers use automated scrubbing software and real-time integration.
Manual processing just doesn’t scale.
What Percentage Numbers Are Typically Flagged as DNC
This surprises many marketers.
A large portion of consumer data is already registered.
Industry averages show:
- Fresh consumer lists → 15–25% flagged
- Aged data → 25–40% flagged
- Old or recycled leads → up to 60% flagged
That means if you buy 10,000 leads, 2,000–4,000 might be legally untouchable.
Calling them blindly is extremely risky.
When and How Often Lead Lists Should Be Scrubbed
Scrubbing isn’t a one-time task.
Best practices include:
- Scrub every new list purchase
- Scrub before each campaign
- Re-scrub every 30 days
- Use real-time scrubbing for dialers
Data changes constantly. People add numbers to DNC daily.
Old “clean” lists quickly become unsafe.
Can You Call a Number That Appears on the DNC Registry?
In most cases, no.
But there are legal exceptions.
Knowing these exceptions is important so you don’t miss legitimate opportunities while still staying compliant.
Cases When You Can Call the Vet When You Want to Call Them
You may legally contact a number on the DNC registry if:
- You have written consent
- There is an existing business relationship
- The customer recently purchased or inquired
- The call is non-marketing (support or service)
- It’s a business-to-business call
Outside of these scenarios, calling is risky and usually illegal.
When in doubt, don’t dial.
Liability Risks of Using Unscrubbed Lead Lists
Using an unscrubbed list is like driving without insurance.
It might seem fine — until something goes wrong.
Risks include:
- $500–$1,500 fine per call
- TCPA lawsuits
- Class action cases
- Carrier blocking
- Account suspension
- Brand damage
Just 50 bad calls could cost tens of thousands of dollars.
Liability of Offshore Call Centers
Many companies think offshore teams protect them legally.
They don’t.
If you target US consumers, US laws apply — regardless of where the calls originate.
Even if an overseas call center makes the mistake, the hiring company is usually held responsible.
Outsourcing doesn’t remove liability.
Cost of DNC Scrubbing at Different Volumes
Good news: scrubbing is cheap.
Very cheap compared to fines.
Typical market pricing:
- 1,000 numbers → $5–$10
- 10,000 numbers → $20–$40
- 100,000 numbers → $150–$300
- 1M+ → bulk discounts
Compare that with $1,500 per violation.
Scrubbing is basically insurance for pennies.
Frequently Asked Questions About US DNC Scrubbing
Is DNC scrubbing mandatory for telemarketers?
Yes. If you are marketing to consumers in the US, DNC scrubbing is not something you can choose to do or not – it is mandatory under federal regulations such as the Telephone Consumer Protection Act (TCPA) and FTC telemarketing guidelines.
If you are a business that engages in promotional or sales calls to residential or wireless numbers, you must make sure that you are not calling people who are registered on the National Do Not Call Registry.
The consequences of not DNC scrubbing your lists include:
- $500 per violation
- Up to $1,500 per willful violation
- FTC enforcement actions
- Lawsuits or class actions
- Carrier blocking or spam labeling
This applies to all businesses, including small businesses or startups. It doesn’t matter if you are making 100 calls per day or 100,000 calls per day. The same rules apply.
If you are engaging in telemarketing as part of your marketing strategy, DNC scrubbing needs to be part of your process before every marketing campaign.
How often should lead lists be scrubbed against the DNC registry?
At least once every 30 days. Ideally, before every campaign.
The National DNC Registry is updated constantly. Thousands of consumers submit their numbers every day. This means that a list that was “clean” last month may already have restricted numbers today.
Because of this, it is not a good idea to rely on old scrubbing results.
Industry best practices include:
- Scrubbing every new list purchase
- Scrubbing before every outbound campaign
- Re-scrubbing existing databases every month
- Using real-time API scrubbing for dialers
If you tend to reuse lists of older leads, you should scrub even more often.
Scrubbing regularly will not only keep you in compliance but also help your performance, as you will avoid wasting time calling people who do not want to be called.
It’s like maintenance – a little work now will save you headaches down the road.
Does DNC scrubbing apply to mobile and VoIP numbers?
Yes. Mobile numbers, as well as landline and VoIP numbers, are all included.
Many marketers have a misconception that DNC regulations only apply to residential landlines, but this is no longer the case. In today’s world, most consumers use mobile phones or internet-based numbers, and these numbers are all protected under US telemarketing regulations.
The registry includes:
- Cell phones
- Residential landlines
- VoIP numbers
- Internet calling services
In fact, mobile numbers have even stricter regulations, especially when using automated dialing systems or pre-recorded messages.
Calling restricted mobile numbers without consent can result in stiffer TCPA penalties.
This is why today’s DNC scrubbing software checks all types of numbers, not just residential landlines. If you are dialing any US number, it must first be scrubbed, regardless of the technology used.
Who is responsible for DNC compliance: the lead seller or the caller?
The caller. Even if you purchase “clean” data, you’re still liable for compliance.
This is one of the most crucial things you must understand.
Lead sellers often claim their lists are:
- “DNC compliant”
- “Scrubbed data”
- “Safe leads”
However, from a legal standpoint, this does not shield you.
You will be held liable if there is a problem.
Regulators and the courts will hold your company accountable, not the lead seller.
This means that you must always:
- Re-scrub the lists yourself
- Keep compliance records
- Keep records of scrubbing
- Never just take the seller’s word for it
Consider third-party lists as unverified until you verify them yourself.
Do DNC rules apply to B2B or business phone numbers?
Generally, no.
B2B calls are often exempt, but mixed lists should still be verified carefully.
Calls made strictly to businesses for business purposes are typically not covered by the National DNC Registry. This is why many B2B sales teams can cold call companies legally.
However, things can get tricky.
Problems happen when:
- A “business” number is actually a personal mobile
- A sole proprietor uses a home phone
- Lists contain mixed B2B + consumer data
- You cannot clearly identify number type
In these situations, calling without verification could still violate regulations.
For safety, many professional telemarketers still scrub all numbers — even B2B — just to avoid risk.
If you’re unsure whether a number belongs to a business or consumer, it’s safer to treat it like a consumer number and scrub it.
What is a DNC Scrubber?
A DNC scrubber is software that automatically compares your list against the registry and removes restricted numbers.
It’s the simplest way to stay compliant and reduce risk.
Instead of manually checking thousands of numbers, a scrubber automates the entire process in seconds.
Most tools allow you to:
- Upload CSV files
- Connect via API
- Run bulk checks
- Flag or remove restricted numbers
- Download a clean list
Advanced scrubbers may also include:
- State DNC databases
- Reassigned number detection
- Wireless number identification
- Internal suppression lists
- Litigator or complaint lists
These features provide extra layers of protection beyond basic compliance.
For any serious call center or lead generation business, a DNC scrubber is not a luxury — it’s essential infrastructure.
Does DNC scrubbing prevent spam labeling by carriers?
Not completely. Scrubbing reduces complaints, which helps reputation, but you also need:
- Proper caller ID
- Good call behavior
- STIR/SHAKEN authentication
- Low complaint rates
Compliance + good practices = better deliverability.
DNC scrubbing helps because it prevents you from calling people who specifically asked not to be contacted — and those people are the most likely to report your calls as spam.
Fewer complaints = better carrier trust.
However, spam labeling depends on more than just DNC compliance.
Carriers also monitor:
- Call volume spikes
- Short call durations
- High hang-up rates
- Repeated redials
- Customer complaints
- Number reputation
So even if your list is perfectly scrubbed, poor dialing behavior can still get your numbers flagged.
Final Thoughts
Telemarketing can still provide an incredible ROI – but only if you follow the rules.
DNC scrubbing is not a hassle. It’s a safeguard.
Investing a few dollars now can save you thousands in the future.
If you’re doing the volume of calls, scrubbing should be part of your regular process – every time.
Because in the world of telemarketing, compliance is not a choice. It’s a matter of survival.
USD $ | United States
