Most calling teams know about the National Do Not Call Registry. Fewer have a solid handle on the other half of the rule: the company-specific (internal) do-not-call list. It is required, it is easy to get wrong on a busy floor, and "we told them we'd stop and then called again" is one of the most common ways a team ends up on the wrong side of a TCPA claim.

Two lists, two jobs

National Do Not Call Registry Your internal do-not-call list
Who adds numbers Consumers, through the FTC's registry Your team, whenever someone asks you to stop
What it blocks Telemarketing to registered consumer numbers, unless an exception applies Any further telemarketing calls from your organization to that person
How you use it Scrub your call lists against it at least every 31 days Check it before every dial, in real time

An existing business relationship or the consumer's express permission can let you call a number that is on the national registry. Neither overrides a direct request to stop. Once someone asks you not to call, they go on your internal list.

What the rules require

The FCC's rules require anyone making telemarketing calls to consumers to have procedures for an internal do-not-call list. The core requirements:

  1. A written policy for maintaining the list, available on request.
  2. Trained staff. Everyone who makes calls must be informed and trained on the list and the policy.
  3. Record every request. When someone asks not to be called, record their name (if given) and number at the time of the request.
  4. Honor it fast. Requests must be honored within a reasonable time, which since April 2025 means no more than 10 business days from the request.
  5. Keep it long enough. A request has to be honored for five years.
  6. Identify yourself. Callers must give their name, the name of the business, and a phone number or address where the business can be reached.
  7. Share it within the business. The request applies to the business the call was made for, including affiliates the consumer would reasonably expect to be covered.

Separately, since April 2025 consumers can revoke consent to robocalls and robotexts by any reasonable means, such as saying "stop calling" on a call or replying to a text, and you must honor it within 10 business days.

Where calling floors slip

  • The request dies with one agent. Agent A hears "take me off your list," makes a note, and Agent B calls the same number next week. The list has to block every agent, instantly.
  • Spreadsheet lists. A shared sheet that gets checked "most of the time" is not enforcement. The check needs to happen in the dialer, before the call rings.
  • Re-imported leads. The same number comes back on a new purchased list, or in a CSV import, and nobody screens it on the way in.
  • Multiple numbers, one person. A customer asks you to stop on their office line and you call their mobile. Record every number you have for someone who opts out.
  • Undocumented exceptions. Occasionally a customer on the list calls you back and asks for a callback. That exception should be written down, with who approved it and why.

Building a list that holds up

  1. One click to add. The agent who hears the request should add the number during the call, with no form to fill in later.
  2. Block at the dialer. Every outbound call checks the list first. Blocked numbers should be skipped automatically, not left to the agent's memory.
  3. Screen on the way in. Check imports, web leads and purchased lists against the internal list before they reach a queue.
  4. Require documented overrides. Any exception needs a request, a reason and an approver, stored with the lead.
  5. Audit it. Periodically sample call logs against the list and fix any gaps.

How Voxa helps

In Voxa, an agent adds a number to your do-not-call list or blacklist with one click from the dialer. Every call is checked against both lists before it rings, blocked leads are skipped automatically in dialer sessions, and new leads are screened as they arrive. Exceptions go through an override request that a manager approves, so there is a record of who allowed a call and why. Voxa also blocks calls outside 8am to 9pm in the lead's own time zone by default.

Voxa enforces your internal list, not the National Do Not Call Registry, so keep scrubbing against the registry through a registry service if you call consumers. For the rules on AI voices specifically, read are AI voices legal on sales calls?.

This article is general information, not legal advice. Talk to a qualified attorney about your do-not-call policy and procedures.