TCPA compliance checker: outbound calling quiet hours, DNC, and consent

What TCPA compliance means for outbound calling

The TCPA compliance checker above runs three live validations against your inputs: a quiet-hour window calculator that converts your dialer time to the called-party local time and overlays state rules, a six-item DNC and consent suppression checklist that scores your exposure tier, and an offshore disclosure decision tree that tracks the FCC's proposed foreign call center rule (FCC 26-16, not yet adopted) and suggests opening wording for your sales and lead-gen calls if any of your agents are based outside the United States.

Outbound calling laws at a glance

Four bodies of law govern a US outbound calling program. The table names each one, who enforces it, what it controls, and the primary source.

TCPA compliance checklist

Ten items, one line each, with the rule behind every one. Tick them off against your own program, then use the three checks above to test the first six live.

• Consent type matched to the call type. For covered telemarketing calls using an automatic telephone dialing system or artificial or prerecorded voice, retain the written consent authorizing the seller and calling method. Source: 47 CFR 64.1200(a)(2) and (f)(9).
• Calling hours gated at 8 AM to 9 PM in the called party's local time, with the twenty state overlays applied (twenty-one from October 18, 2026, when Pennsylvania joins) and holiday rules checked separately. Source: 47 CFR 64.1200(c)(1) and 16 CFR 310.4(c).
• National DNC Registry scrubbed with a version no more than 31 days old. Source: 16 CFR 310.4(b)(3)(iv) and 47 CFR 64.1200(c)(2)(i)(D).
• Internal do-not-call list maintained and scrubbed on every campaign. Source: 47 CFR 64.1200(d).
• State do-not-call lists scrubbed for every called-party state that keeps one. Source: the 51-jurisdiction table on this page.
• FCC Reassigned Numbers Database queried against your consent date. Source: 47 CFR 64.1200(m) safe harbor.
• Caller ID transmitted on every call, never blocked, showing a number that accepts do-not-call requests. Source: 47 CFR 64.1601(e) and 16 CFR 310.4(a)(8).
• Every opt-out recorded when it is made and honored as soon as reasonably possible, no later than 10 business days, and kept on the list for five years. Source: 47 CFR 64.1200(d)(3) and (d)(6).
• Records retained for five years: scripts, prerecorded messages, a record of each call, and consent evidence. Source: 16 CFR 310.5(a).
• Offshore location disclosed in the opening when any agent on a B2C sales or lead-gen campaign works outside the US. Source: best practice, not yet a federal rule; the FCC proposed a disclosure in FCC 26-16 (March 2026). Tested in Check 3 above.

The federal floor: 8:00 AM to 9:00 PM called-party local time

47 CFR 64.1200(c)(1) prohibits telephone solicitations before 8:00 AM or after 9:00 PM at the called party's location. The clock is the consumer's local time, not the agent's, not the dialer's, not the company HQ's. A dialer in Caribbean Eastern time placing a call at 8:30 AM to a California (Pacific) consumer is dialing at 5:30 AM Pacific, which is a TCPA violation regardless of the agent's local clock. Production dialers must geocode every record by area code or street address and gate dial decisions on the called-party time zone.

The FTC Telemarketing Sales Rule (16 CFR 310.4(c)) mirrors the same 8-to-9 window for B2C telemarketing. The two rules are functionally identical, but enforcement is split: FCC enforces against carriers and dialers, FTC enforces against marketers, and state attorneys general piggyback on both with state-specific damages.

State overlay rules table

Twenty states tighten the federal 8-to-9 window as of October 10, 2026. The common tightenings are a later start (9 AM in Connecticut, Michigan, Minnesota, Nevada, New Mexico, South Dakota, Texas and on Rhode Island weekdays; 10 AM in Kentucky), an earlier end (8 PM in Alabama, Connecticut, Florida, Louisiana, Maryland, Massachusetts, Mississippi, Nevada, Oklahoma, Oregon, Washington and Wyoming; 6 PM on Rhode Island weekdays), and weekend or holiday rules (no Sunday calls in Alabama, Louisiana, Mississippi, Rhode Island, South Dakota and Utah; a noon Sunday start in Texas; 10 AM to 5 PM on Rhode Island Saturdays; no holiday calls in Alabama, Louisiana and Utah, or in Rhode Island when the holiday falls on a weekday). Pennsylvania joins them on October 18, 2026, when Act 47 of 2026 sets 9 AM to 7 PM Monday to Saturday with no Sunday calls; its ban on legal holiday calls is already in force.

The other 30 states plus DC sit on the federal 8 AM to 9 PM window as of October 10, 2026 (29 states plus DC from October 18, 2026). The FCC call-time rules deep dive walks through how dialers should encode these per-state overlays.

Outbound calling windows for all 51 US jurisdictions

The summary table above lists the 20 states that tighten the federal calling window as of October 10, 2026, plus Pennsylvania's window from October 18, 2026. The complete table below covers all 50 states plus the District of Columbia, including the four jurisdictions that keep the federal 8 AM to 9 PM window but impose stricter consent, recording, or state do-not-call obligations on top of it: California, Indiana, New York, and Tennessee. Every window is stated in the called party's local time. The validator above checks the day of the week, not the date, so holiday rules sit in the notes: Alabama, Louisiana, Pennsylvania, Rhode Island (weekday holidays) and Utah, plus Nebraska for prerecorded calls.

Outbound telephone solicitation calling windows by US jurisdiction, 2026. Units: permitted calling window in local time at the called party's location. Scope: all 50 US states plus the District of Columbia, 51 rows. Basis: the federal floor of 8 AM to 9 PM under 47 CFR 64.1200(c)(1) and 16 CFR 310.4(c), with stricter state windows controlling where they exist. Compiled by Call Force Global from the cited federal rules and state telemarketing statutes, 2026; last reviewed October 10, 2026 against state statutes, codes and agency orders. Informational only, not legal advice; confirm current state rules with counsel before configuring a dialer.

How to cite this table: Call Force Global. (2026). US Outbound Calling Windows by State, 2026. Retrieved from https://callforce.global/tools/tcpa-compliance-checker/

How to run a DNC check: three routes

A DNC check means one of three jobs, depending on whose number you are checking and how many. Each has its own route.

1. Your own number. Use the FTC's verification page at donotcall.gov: enter up to three phone numbers and your email address, and the FTC emails back whether and when each one was registered. You can also call 1-888-382-1222 from the phone you want to check. A new registration shows on the registry the next day, but it can take up to 31 days for sales calls to stop.
2. A few prospects. A seller or telemarketer that has registered, certified and paid any fee due at telemarketing.donotcall.gov can check 10 or fewer numbers at a time on the registry's interactive pages. There is no fee to subscribe to five or fewer area codes, so a small-volume caller can use this route without downloading a whole area code (FTC Q&A for telemarketers and sellers).
3. A whole calling file. Download the registered numbers for every area code you call, or have a service provider scrub the file under your own subscription account number, and refresh the scrub at least every 31 days under 16 CFR 310.4(b)(3)(iv). Then suppress the state do-not-call lists for every state you call and your own internal do-not-call list, neither of which the federal download covers.

This tool does not look up any number and never asks for one. It checks the campaign around the lookup: whether your calling windows, DNC suppression process and consent records would hold up, which is the part a registry lookup cannot tell you.

How does the DNC list work?

The National Do Not Call Registry works as a suppression list: consumers add their numbers for free, and sellers and telemarketers download the registered numbers for the area codes they call and remove them from their calling lists before dialing. A consumer registers at donotcall.gov, or by calling 1-888-382-1222 from the phone being registered, and the registration never expires. A new number can take up to 31 days to stop sales calls, and a telemarketer has to work from a copy of the registry no more than 31 days old under 16 CFR 310.4(b)(3)(iv).

The registry covers sales calls only. Political calls, charitable calls, debt collection calls, purely informational calls and surveys are allowed as long as they carry no sales pitch, and a company can still call a registered number if the consumer recently did business with it or gave written permission. State registries and your own internal do-not-call file sit on top of the federal list, which is why the next section names four lists rather than one.

DNC suppression: four lists you must scrub

1. Federal DNC. The National Do Not Call Registry. Subscribers can register their numbers and a telemarketer must scrub the registry every 31 days for calls under the FTC TSR and 47 CFR 64.1200. Exceptions: established business relationship (EBR) within 18 months, written consent, charitable, political, or survey calls.
2. State DNC. Several states maintain their own DNC registries in addition to federal (notable examples: Indiana, Tennessee, and select others). Operators dialing nationwide must subscribe to and scrub against every active state list, not just federal. Wyoming keeps no registry of its own; its statute instead bars calls to numbers on the Direct Marketing Association Telephone Preference Service list.
3. Internal company DNC. Every prior opt-out, hang-up-equals-stop, and any consumer who has asked your company specifically not to call again. Required separately from federal under 47 CFR 64.1200(d). Internal DNC is the most-overlooked list in BPO programs; auditors check it first.
4. FCC Reassigned Numbers Database (RND). Live since November 2021. Catches numbers where the subscriber has changed since you captured consent. If you call a number after the original consenting party gave up the line and a new consumer took it, you are calling without consent. RND query gives a safe-harbor defense.

Best-practice (not required): scrub against litigator and serial-plaintiff lists. A handful of vendors maintain lists of known TCPA plaintiffs whose lawsuits drive most class actions. Scrubbing these out is a cheap exposure hedge.

Reassigned Numbers Database (FCC RND)

The RND launched November 2021 and resolved a decade of litigation ambiguity about reassigned-number calls. Before RND, callers who reached a number whose subscriber had changed faced strict-liability TCPA exposure even when they had captured valid consent from the original holder. RND gives callers a safe-harbor: query the RND for the date your consent was captured, get a yes/no on whether the number was reassigned, and if RND reports no reassignment between consent date and call date, you have a defense.

Operators integrate RND in two patterns. Batch scrub (monthly or weekly) is cheaper. Real-time query at dial-time is more expensive but lower latency on lead-list freshness; recommended for high-volume B2C programs where leads age fast.

Prior express written consent for autodialed and prerecorded calls

The TCPA distinguishes between two consent standards. For ordinary, manually-dialed informational calls, plain consent is sufficient. For autodialed or prerecorded calls to mobile phones placed for marketing purposes, the higher bar of prior express written consent applies under 47 USC 227(b)(1)(A). The written consent must clearly identify the seller, disclose that the call will be made using an automated dialing system or prerecorded voice, list the specific phone number being authorized, and not be a condition of purchase.

The Eleventh Circuit vacated the FCC's 2023 one-to-one consent restrictions on January 24, 2025. Those restrictions did not take effect in 2024. The ruling did not remove existing written-consent requirements for covered marketing calls. Operators using lead vendors should retain the agreement and check that it authorizes their seller, phone number and calling method. The TCPA outbound voice guide covers the related documentation workflow.

Offshore disclosure: what the FCC has proposed

The location-disclosure provisions discussed here come from a proposed rule. The notice does not itself create a disclosure obligation; other requirements depend on the sector and jurisdiction. In FCC 26-16, a notice of proposed rulemaking adopted March 26, 2026, released March 27 and published in the Federal Register on April 23, 2026, the FCC proposed requiring telecommunications, wireless, interconnected VoIP, cable and satellite TV providers and their affiliates to tell customers at the start of each call handled at a foreign call center that it is being handled outside the United States, and to transfer the call to a US call center on request. It also asked whether some or all of the rules should reach other kinds of companies. The notice was filed in several dockets, including CG Docket 02-278, the FCC's main TCPA docket, which is why it gets described as a 02-278 rule. After a one-week extension, reply comments closed June 29, 2026. Check the current docket before treating a proposal as an adopted requirement.

A voluntary location disclosure can be included in scripts for consumer (B2C) sales and lead generation, B2B, or inbound customer service, though state telemarketing rules may still apply. Operators running nearshore or offshore programs that want to stay ahead of the proposal can put a short disclosure in the opening script and score it in QA, for example: Some of our customer service agents may be located outside the United States. The FCC CG Docket 02-278 compliance checklist walks through buyer-side controls.

What happens if you call a number on the DNC list?

Calling a number on the National Do Not Call Registry without an exemption or written permission is a telemarketing violation, and under 47 USC 227(c)(5) a consumer who gets more than one such call from the same company within 12 months can sue for statutory damages on each call. A caller that keeps written do-not-call procedures, trains its staff and dials against a registry copy no more than 31 days old has a defense for a call placed in error under 47 CFR 64.1200(c)(2)(i). Regulators can pursue the same call separately, as the penalties below show.

TCPA statutory damages are $500 per violation, and 47 USC 227(b)(3) lets a court raise the award to three times that amount for willful or knowing violations. There is no cap on aggregate exposure. Class certification is routine in TCPA cases because the harm (an unwanted call) is identical across class members, so a class covering a hundred thousand wrongly dialed calls multiplies the statutory minimum into eight-figure exposure.

FTC TSR violations carry civil penalties of up to $53,088 per violation under 15 U.S.C. 45(m)(1)(A), the inflation-adjusted amount in force since January 17, 2025. The FTC's September 15, 2026 notice keeps that amount for 2026, because the 2026 inflation adjustment was cancelled. State attorneys general can bring parallel actions. The FCC itself enforces via Notice of Apparent Liability (NAL) proceedings with consent decrees often in the seven to eight figures for repeat offenders.

The tech-enabled compliance approach

Compliance is not a binder of policies; it is dialer configuration plus consent ledger plus automated suppression. The CFG operational pattern stacks four controls:

• Dialer-side quiet-hour gating. Every record carries a called-party time zone (geocoded at lead capture). The dialer refuses to place a call outside the 8 AM to 9 PM local window plus any active state overlay. Manual override is logged and supervisor-approved only.
• Automated DNC scrubbing. Federal DNC scrubbed every 31 days. State DNC scrubbed every 31 days. Internal opt-outs recorded when received and honored as soon as reasonably possible, no later than 10 business days. RND queried in batch or at dial-time depending on program volume.
• Seller-specific consent ledger. Every lead carries a consent record tied to a single seller. Lead-vendor leads are rejected unless the consent record names your specific company.
• Offshore disclosure baked into opening. If any agent on the campaign is located outside the US, the disclosure is in the first 10 seconds of the call script and QA-scored every call.

The structural advantage of running outbound from a Caribbean nearshore fronter perimeter is timezone alignment. Caribbean ET is the same as US ET. Agents dialing US ET consumers in the morning are not battling the 11-to-13 hour shift inversion that drives offshore burnout and creates compliance lapses when night-shift agents drift outside the called-party window.

FAQ

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For deeper reading: TCPA compliance for call center outsourcing, FCC outbound calling regulations 2026, FCC call-time rules deep dive, TCPA outbound voice 2026, outsourced TCPA training for voice agents, and the FCC CG Docket 02-278 compliance checklist. For verticals where TCPA exposure is heaviest, see our debt collection outsourcing, solar pilot, and B2B SDR pilot. To talk to our compliance lead, head to contact.