Cold Calling Compliance & Do-Not-Call Checklist

This is an operational checklist, not legal advice. Telemarketing law varies by state and country and changes over time. Have counsel review your specific program, scripts, and list sources before launch - use this to make sure the right questions get asked.

1. Pre-Campaign Setup

• Company is registered with the National Do-Not-Call Registry (if calling US consumers) and has paid the applicable access fee
• Calling list has been scrubbed against the National DNC Registry within the last 31 days
• Internal, company-specific Do-Not-Call list exists and is checked before every dial
• Caller ID transmits the company's real name and a working callback number
• Any third-party list source has provided written confirmation of how consent/opt-in was obtained

2. National DNC Registry

• Existing Business Relationship (EBR) exceptions are understood and time-boxed (commonly 18 months from last purchase/transaction, 3 months from an inquiry - confirm current thresholds with counsel)
• Scrub cycle is on a recurring calendar (every 31 days) with an owner and a completion log
• Numbers added to the internal DNC list are suppressed immediately, not on the next scrub cycle
• DNC suppression records are retained per your counsel's guidance (commonly several years)

3. TCPA / Autodialer & Prerecorded Message Rules

• Confirmed whether your dialer technology qualifies as an Automatic Telephone Dialing System (ATDS) under current TCPA interpretation
• Prior express written consent is on file before any autodialed or prerecorded call/text to a mobile number for marketing purposes
• Manual, human-initiated calls (no autodialer, no prerecorded message) are documented as such if relying on the manual-dial exception
• Legal has reviewed any AI-assisted or predictive dialing technology against current ATDS guidance before rollout

4. Call Recording Consent

• Confirmed whether each state you call into requires one-party or all-party (two-party) consent to record
• All-party consent states are flagged in the dialer/CRM so reps get a disclosure prompt automatically
• Verbal recording disclosure is scripted at the top of the call before recording begins ("This call may be recorded for quality and training purposes")
• Recording disclosure is logged as part of the call record, not just spoken
• Commonly-cited all-party consent states are documented on your internal reference (e.g., California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, Washington) - confirm current statute text with counsel, as lists shift

5. Time-of-Day & Frequency

• Calling window is restricted to 8:00am-9:00pm in the recipient's local time zone, not the caller's
• Dialer/CRM enforces the time-zone restriction automatically rather than relying on rep judgment
• Call frequency caps exist so the same number isn't dialed an excessive number of times per day/week
• Opt-out requests ("please don't call again," "take me off your list") are honored immediately and logged the same day

6. Data & Record-Keeping

• Call disposition, consent status, and opt-out requests are logged in the CRM, not just in a rep's notes
• List source, acquisition date, and consent basis are documented for every list loaded into the dialer
• Records are retained per counsel's guidance in case of a complaint or audit
• A named compliance owner reviews the DNC/TCPA checklist at least quarterly

7. International Add-On (UK & Canada)

• UK: numbers screened against the Telephone Preference Service (TPS) unless a documented soft opt-in applies; calls comply with PECR marketing-call rules
• UK: abandoned/silent call rate is monitored and kept under Ofcom's permitted threshold
• Canada: numbers screened against the National Do Not Call List (DNCL); CRTC unsolicited telecommunications rules reviewed for autodialer/recorded-message calls
• Cross-border calling campaigns have a named owner for each jurisdiction's rules, not a single US-only compliance owner

8. Team Training & Sign-Off

• Every rep completes DNC/TCPA/recording-consent training before their first live dial
• Training completion is logged with date and rep name
• Script includes the required disclosures (company name, purpose, recording notice) as a non-editable opening block
• New reps' first 2 weeks of calls are spot-reviewed for compliance disclosures, not just talk-track quality
• Compliance checklist owner re-certifies the program after any material change to dialer technology, list source, or calling geography

Disclaimer: This checklist is an operational aid for sales and revenue leaders, not a substitute for legal review. TCPA, state consent laws, and international telemarketing regulations change and carry real financial exposure per violation - have qualified counsel review your specific program before launch.