Quick Answer (TL;DR):
An Internal DNC List is a company-maintained database of consumers who have directly requested that a specific organization stop contacting them via phone or SMS, regardless of whether the number is on the National DNC Registry.
The Statutory Rule:
Under 47 C.F.R. ยง 64.1200(d), any business placing telemarketing calls must maintain a written policy for maintaining a company-specific do-not-call list, train personnel on its use, and honor opt-out requests within a reasonable time frame (not to exceed 10 business days for automated systems).
Operational Implication:
- Omnichannel Suppression: An opt-out received on any channel (voice, SMS, email, or chat) must automatically propagate across all company dialing systems and external vendor platforms.
- Retention Duration: Company-specific DNC requests must be honored for a minimum of 5 years from the date of the request.
- Zero-Tolerance Rule: Calling an internal DNC number bypasses Established Business Relationship (EBR) exemptions and constitutes an immediate violation.
Related Guide:
Build compliant opt-out infrastructure with our TCPA compliance checklist for outbound campaigns (2026 update).