Call Center Compliance — Registry Mechanics

What Is a SAN Number? The Subscription Account Number, Explained

A SAN number — Subscription Account Number — is the account identifier the FTC issues when your organization subscribes to National Do Not Call Registry data at telemarketing.donotcall.gov. It matters because under 16 C.F.R. § 310.8, a seller may not call any number within an area code — on the registry or not — until it has paid the annual fee for that area code. Below: who needs a SAN, the FY2026 fees, how to get one, who is exempt, and the enforcement math — as of July 2026.

This page is education, not legal advice. The dialer itself is compliant software, but compliance depends on user behavior — the SAN, the fees, and the scrub schedule are the seller’s responsibility. Enzo does not scrub lists against the national or state DNC registries — use a third-party scrubbing service before uploading any list. Enzo provides campaign-level internal DNC (per-campaign only). Consult a telemarketing attorney for your specific program.

Who Must Have One: One SAN Per Seller

The registry has a consumer side and a caller side: consumers register numbers free, and callers subscribe to the resulting data — the SAN identifies that caller-side subscription. The unit of subscription is the seller — the company whose product the calls promote — not the call center, the agency, or the software.

• Every seller needs its own subscription and SAN. A telemarketer may not use registry data to call on behalf of more than one seller unless each holds its own subscription, per the FTC’s telemarketer Q&A — and a telemarketer downloading data for clients must supply each client’s SAN.
• Cost-sharing is prohibited. 16 C.F.R. § 310.8(c) bars dividing registry access costs among a telemarketer’s or service provider’s clients.
• An agency can do the paperwork — completing the subscription and obtaining the SAN at the seller’s direction — but the subscription belongs to the seller. Selling for three brands means three SANs.

The Rule With Teeth: Unpaid Area Codes Are Off-Limits Entirely

It is a Telemarketing Sales Rule violation for a seller to call — or cause a telemarketer to call — any number within an area code unless the seller first paid the annual fee for that area code (16 C.F.R. § 310.8(a)–(b)). The prohibition applies even to numbers not on the registry.

So SAN coverage is defined by where you dial, not by whose numbers are registered. Check a new metro’s area codes are on the subscription before dialing it — the registry spans all 50 states, D.C., the territories, and the toll-free codes.

FY2026 Fees and the Per-Area-Code Math

For the fee year that began October 1, 2025, per the FTC’s published FY2026 fee schedule and 16 C.F.R. § 310.8(c)–(d):

The subscription runs twelve months beginning on the first day of the month in which the fee was paid (16 C.F.R. § 310.8(d)). Fees adjust every October 1 — FY2027 figures will publish in late 2026, so verify current numbers before renewing.

What that means at typical footprints:

How to Get a SAN, Step by Step

1. Create a profile at telemarketing.donotcall.gov, identifying your organization as a Seller, a Telemarketer/Service Provider, or an Exempt Organization.
2. Certify that you will access the registry solely to comply with the TSR or to prevent calls to registered numbers.
3. Select area codes — the first five are free — and pay any required fee through Pay.gov.
4. Download data. Full files pull only once per 24 hours; smaller “change list” delta files follow, and the FTC recommends a full refresh at least every six months.
5. Put the scrub on a calendar. The safe harbor requires a registry version obtained no more than 31 days before any call (16 C.F.R. § 310.4(b)(3)(iv); the FCC’s parallel rule is 47 C.F.R. § 64.1200(c)(2)(i)(D)) — the full caller-side workflow lives in the DNC registry guide.

Who Doesn’t Need to Pay — and the Catches

Consent-and-EBR-only callers. Section 310.8’s proviso drops the payment requirement for a seller that calls solely people covered by prior express written agreement or an established business relationship, and never accesses the registry for any other purpose. The catches: an EBR lasts 18 months from a purchase or 3 months from an inquiry, a company-specific do-not-call request ends it, and one cold call outside those categories puts you back inside the fee requirement.

Exempt organizations. Charities and political callers pay no fee and may take the entire list free, though their SAN issues only after a waiting period that begins the next business day after profile completion — roughly three business days.

Pure B2B programs. The registry covers personal phone numbers only — business and fax lines are not covered, and most B2B solicitation calls are exempt from the DNC provisions. The trap: a decision-maker’s personal cell is a wireless number no matter how they use it.

A SAN Covers the Federal Registry Only

A federal SAN does nothing for the states that sell their own quarterly lists. Texas, the largest, charges $200 per quarter per list per the official Texas No Call telemarketer FAQ as of July 2026 — confirm before subscribing, and see the Texas Do Not Call list guide. Nor does the SAN scrub anything: it gets you the data, a scrubbing service applies it, and a DNC checker spot-verifies individual numbers.

Enforcement Reality

Calling in an unpaid area code is itself a TSR violation — separate from any violation for calling a registered number. The FTC’s civil penalty is currently up to $53,088 per violation under 16 C.F.R. § 1.98(c) (adjusted annually for inflation — verify the current figure), a figure the FTC’s own DNC guidance applies per violating call. Private TCPA plaintiffs add their own track at $500 to $1,500 per call, no regulator required — $82 per area code is not a corner worth cutting.

Where Enzo Fits — and Where It Doesn’t

Enzo has no role in the SAN system, on purpose. It does not subscribe for you, hold registry data, or scrub lists against the national or state registries — subscribe under your own SAN, scrub through a third-party service, then import the clean CSV. Enzo provides campaign-level internal DNC: mark a contact DNC and they stay excluded from that campaign, even if they reappear in another list uploaded to it. Marks do not carry across campaigns — keep your master suppression file outside the dialer and re-apply it to every new campaign.

The SAN, reduced to a checklist: one subscription per seller, every area code covered before you dial it, renewal on a twelve-month clock, and fresh downloads feeding a scrub at least every 31 days. It is the most mechanical piece of DNC compliance — and the one the FTC can verify from its own records.

See how campaign-level DNC fits a real calling workflow — book a free discovery call.

Not legal advice. This guide is general information for outbound calling teams, not legal advice. Rules change and apply differently by state, industry, and call type — confirm your program with qualified telemarketing compliance counsel.

Fees and rules from the FTC’s FY2026 fee schedule, 16 C.F.R. §§ 310.4, 310.8, and 1.98, and the FTC’s Q&A for Telemarketers & Sellers, as of July 2026; registry fees change every October 1. Company names are trademarks of their owners. Educational only, not legal advice.