Washington state do not call list: rules, registration, and penalties

Last updated 2026-07-10

What is the Washington state do not call list?

Washington runs its own do not call registry under Revised Code of Washington section 80.36.390 ^[1]. The Washington Utilities and Transportation Commission (UTC) administers it. Registrations on the Washington list are separate from the federal National Do Not Call Registry that the FTC maintains ^[2]. A consumer who signs up with the FTC is not automatically on the Washington list, and the reverse is true too.

That gap matters for outbound sales teams. You have to check both lists, every time, before a campaign drops. Miss either one and you generate a complaint. Complaints turn into fines.

The Washington law covers residential landlines and mobile numbers. It applies to any telemarketer who calls a Washington phone number to sell goods or services. If you call into Washington, you are subject to this law no matter where your company sits.

How does the Washington DNC law differ from the federal TCPA?

The federal Telephone Consumer Protection Act (47 U.S.C. § 227) sets a national floor ^[3]. States layer their own rules on top, and Washington does. The federal TCPA mostly targets the method of calling: autodialers, prerecorded messages, prior express consent. Washington's law is about the registry itself and about making telemarketers honor a consumer's do not call request. Both apply at the same time when you call a Washington number.

Issue	Federal TCPA / FTC Rule	Washington RCW 80.36.390
Registry admin	FTC (National DNC Registry)	Washington UTC
Penalty per violation	Up to $500 civil; up to $1,500 trebled	Up to $1,000 per violation
Who can sue	FTC, state AGs, private plaintiffs	State AG, private plaintiffs
Mobile numbers covered	Yes (TCPA also restricts autodialing)	Yes
Business-to-business	Exempt from FTC DNC rules	Generally exempt
Safe harbor (internal DNC)	31-day scrub cycle required	Same scrub requirement

You do not pick one or the other. You comply with both.

Enforcement is where the two laws genuinely split. A private plaintiff suing under the TCPA can collect $500 per call and up to $1,500 per willful violation without proving actual damages ^[3]. Washington's private right of action runs through the Consumer Protection Act (RCW 19.86), which allows actual damages trebled up to $25,000 for a willful violation, plus attorney fees ^[4]. That fee shifting is why plaintiff attorneys in Washington sometimes prefer state court.

How do consumers register on the Washington do not call list?

Consumers register through the Washington UTC website ^[1]. Registration is free. You can sign up online or by calling the UTC directly. Once a number is on the list, it stays there until you take it off. There is no expiration and no rolling re-registration like some older state lists used to require.

The UTC says registrations take effect within 30 days of submission. Sign up on July 1, and telemarketers are expected to honor that registration by July 31 at the latest.

Still getting calls after you registered? File a complaint. You can do that at the UTC website or through the FTC's donotcall.gov ^[2]. Write down the date, time, caller ID, and what the caller said. That record is what gives an investigator something to work with.

What exemptions apply to Washington's do not call rules?

Not every call to a Washington number triggers the list requirement. Exemptions under RCW 80.36.390 and the related Washington Administrative Code rules include four main categories.

1. Calls to existing customers. If someone has an established business relationship with your company (18 months from a purchase, 3 months from an inquiry), you can call them even if they are on the list, unless they have told you to stop. This mirrors the federal EBR exemption.

2. Calls where the consumer gave prior written consent. Documented, clear written consent to call overrides the list registration.

3. Calls that are not commercial. Political calls, charitable solicitations, and surveys are generally not "telephone solicitation" under the statute, so the DNC list does not restrict them. This does not mean those calls are unregulated. Other laws apply. It just means this registry does not reach them.

4. Business-to-business calls. The Washington list protects consumers, not businesses. Calls to business numbers are not covered.

Don't treat these as loopholes. The EBR exemption has a hard limit: if the customer tells you to stop calling, that kills the exemption immediately and permanently for that customer ^[3]. Log the number on your internal DNC list the same day.

What penalties can telemarketers face for violating Washington's do not call rules?

Washington's statutory penalty is up to $1,000 per violation under RCW 80.36.390 ^[1]. Each call to a number on the list is a separate violation. Drop 500 calls to registered numbers and the arithmetic gets ugly.

Beyond the UTC penalties, the Washington Attorney General can pursue companies under the Consumer Protection Act (RCW 19.86.090) ^[4]. Per-violation fines stack, and the AG can seek injunctive relief, meaning a court order that forces you to stop calling. In serious cases the AG has pursued multi-million-dollar settlements against repeat offenders ^[10].

Private individuals can sue too. A Washington consumer who gets a call in violation of state law can bring a private action. The Consumer Protection Act lets plaintiffs recover actual damages, trebled up to $25,000 for a willful violation, plus attorney fees ^[4]. That fee shifting is exactly why plaintiff firms take these cases on contingency when the violation is clean.

Here is the pattern that sinks small teams. One consumer complaint reaches the UTC. The UTC audits. The audit finds the company skipped list scrubbing entirely. Now the company is defending hundreds of violations at once, at $1,000 a call.

How should telemarketers scrub against the Washington DNC list?

Compliance runs in three layers, and you need all three.

First, register for the Washington UTC list. The UTC provides the list to telemarketers through a formal access process ^[1]. You apply and pay a fee. Fees are set by the UTC and change, so check the current schedule at the UTC website.

Second, scrub the federal National Do Not Call Registry through the FTC's telemarketer access portal at donotcall.gov ^[2]. The federal registry charges an annual access fee based on area codes. If you are calling into Washington, pull the Washington area codes: 206, 253, 360, 425, 509, 564.

Third, keep your own internal do not call list. Any consumer who tells your company directly to stop calling goes on that list immediately. You must honor the request within 30 days and keep the number suppressed for at least five years under federal rules ^[2]. Washington applies a similar standard.

The cycle is the part teams forget. Under FTC rules, telemarketers must update their list data at least every 31 days ^[8]. Let the data age past that window and you have a compliance failure, even if the first scrub was clean.

Build scrubbing into the campaign setup checklist as a recurring calendar event, not a one-time pre-launch task. Nobody has clean data on how often small teams actually scrub on the 31-day cycle, but enforcement actions keep naming companies that scrubbed once at launch and never again.

Want a fast way to check whether a number is on the do not call list before a campaign? LeadCompliant has a free number checker that runs against the federal registry. Washington-specific scrubbing still needs direct UTC access, but the federal check is a starting point.

For how to pull access to the federal registry, see how do i get the do not call list.

Does the Washington DNC list cover cell phones and text messages?

Yes on cell phones. RCW 80.36.390 covers mobile numbers the same way it covers residential landlines. A consumer can register a cell phone on the Washington list, and a telemarketer calling that number to sell something is covered.

Texts are a grayer area under state law, but not under the TCPA. The federal TCPA applies to text messages sent using an automatic telephone dialing system and requires prior express written consent for marketing texts to cell phones ^[3]. The FCC treats text messages as "calls" under the TCPA. So texting a Washington number for marketing gives you both TCPA liability and Washington exposure.

The practical rule is simple. Treat a Washington cell number on the DNC list as off-limits for outbound calls and promotional texts unless you have clear prior express written consent.

For mobile-specific rules, see mobile phone do not call list.

How does Washington compare to other state do not call lists?

Washington is one of roughly 30 states that ran a separate state DNC list at some point, though program activity varies a lot by state. Some states deferred entirely to the federal registry. Others, like Washington, kept independent lists with real penalties attached.

State	Separate state list	Per-violation penalty	Private right of action
Washington	Yes (UTC)	Up to $1,000	Yes (via CPA)
Florida	Yes (FLDNC)	Up to $10,000	Yes
Indiana	Yes	Up to $10,000	Yes
Pennsylvania	Yes	Up to $1,000	Yes
California	Relies on federal	Federal + CCPA overlap	Yes (TCPA, UCL)

Florida and Indiana carry higher headline maximums than Washington. But Washington's Consumer Protection Act trebling means real exposure can run well past the $1,000 figure on the tin. See how other states handle this in the articles on the florida do not call list and indiana do not call list.

The lesson for multi-state callers is blunt. Federal compliance is not enough. Every state you call into adds its own layer. Run national campaigns and you need a state-by-state compliance map, more than a federal scrub.

What should a business do if it receives a complaint or demand letter related to Washington DNC calls?

Stop calling the number immediately. Add it to your internal DNC list the same day. That is not an admission of liability. It is damage control.

Then audit your records. Pull every call log, every scrub record, and every consent document tied to that number and to the campaign that generated the complaint. A demand letter after one complaint is often a warning that more are coming. If your scrubbing process was broken, you want to know now, not after the third letter.

Talk to an attorney who handles TCPA and state consumer protection defense before you answer any demand letter. Plaintiff attorneys in this space send templated letters fishing for quick settlements. Some claims are legitimate. Some overreach. Your response to the first letter sets the tone, so it should be neither a panicked apology nor a dismissive silence.

If the complaint came through the UTC, respond to any UTC inquiry promptly and accurately. Regulators treat non-response or half-answers as aggravating factors. Cooperating while contesting liability generally goes better than stonewalling.

For tracking and reporting complaints, do not call list report has a practical walkthrough.

How do established business relationships (EBR) work under Washington's DNC rules?

The established business relationship exemption lets a company call someone on the DNC list when there is a recent genuine relationship. Under the federal rule, the windows are 18 months from the last purchase and 3 months from the last inquiry ^[2]. Washington tracks that federal framework.

The EBR has two hard limits. First, time. Once 18 months pass since a purchase (or 3 months since an inquiry) with no new transaction, the EBR expires and the DNC registration controls again. Second, the consumer can end the EBR at any moment by telling your company to stop calling. That opt-out overrides even a fresh 18-month window.

Documenting the basis for each EBR call is the real burden. If a complaint lands six months after a sale, you need the record of that transaction date to defend the exemption. If your CRM does not tie transaction dates to phone numbers, fix that before you lean on the EBR at all.

The FTC's EBR guidance sits in the Telemarketing Sales Rule at 16 CFR Part 310 ^[5]. The FCC's parallel guidance under the TCPA is at 47 CFR 64.1200 ^[6]. Washington's administrative rules line up with both.

Where can telemarketers and consumers get help with Washington DNC compliance?

For consumers, two reporting channels matter: the Washington UTC (utc.wa.gov) ^[1] and the FTC's National Do Not Call Registry at donotcall.gov ^[2]. File with both if a call breaks federal and state rules. The FTC keeps a complaint database it shares with state partners, so a federal complaint does reach Washington authorities.

For telemarketers, the UTC website has the registration process for list access ^[1]. The FTC's telemarketer portal for the federal registry is at donotcall.gov ^[2]. Both require registration before you can download suppression data.

The DNC rules themselves are detailed in the FTC's Telemarketing Sales Rule at 16 CFR Part 310 ^[5], and the TCPA's autodialer and prerecorded call requirements are at 47 U.S.C. § 227 ^[3]. To read the actual state statute, RCW 80.36.390 is on the Washington State Legislature's website at leg.wa.gov ^[7]. For AG enforcement, the Washington Office of the Attorney General handles Consumer Protection Act cases ^[10].

The LeadCompliant compliance kit covers the scrubbing checklist, consent templates, and an internal DNC policy you can adapt for a Washington program. Worth grabbing if you are building your process from scratch.

For a broader look at the dnc registry and how to access it, that article walks through the federal side.

Frequently asked questions

How do I register my phone number on the Washington state do not call list?

Go to the Washington UTC website (utc.wa.gov) and follow the Do Not Call registration link. Registration is free. You can register a residential landline or a mobile number. The registration takes effect within 30 days, after which telemarketers who call you in violation of the list face penalties up to $1,000 per call under RCW 80.36.390.

Is the Washington state do not call list the same as the federal do not call list?

No. They are separate systems run by different agencies. The federal National Do Not Call Registry is run by the FTC. The Washington list is run by the Washington UTC. Registering with one does not register you with the other. For full protection, sign up for both. Telemarketers calling Washington numbers must scrub against both lists before calling.

How long does a Washington DNC registration last?

Washington DNC registrations do not expire. Once you register a number, it stays on the list until you remove it. That differs from the early days of some state lists that required periodic re-registration. If you change phone numbers, register the new number separately. The old registration does not transfer to a new line.

Can a company still call me in Washington if I have an established business relationship?

Yes, with limits. If you made a purchase from the company within the last 18 months, or made an inquiry within the last 3 months, it can call you even with your number on the DNC list. But if you tell them to stop, they must honor that immediately and permanently, even inside an active EBR window. The EBR never overrides a direct opt-out.

What is the penalty for calling someone on the Washington do not call list?

Up to $1,000 per violation under RCW 80.36.390. Each call to a registered number counts as a separate violation. The Washington AG can also act under the Consumer Protection Act (RCW 19.86), which allows treble damages up to $25,000 per willful violation plus attorney fees. A pattern of violations can also draw injunctive relief on top of the money.

Do political calls and charity calls have to follow the Washington DNC list?

No. Political calls, charitable solicitations, and surveys are generally not "telephone solicitation" under RCW 80.36.390, so the DNC registry does not restrict them. Those calls still face other rules, including federal disclosure requirements and robocall restrictions. The exemption is narrow. It applies to the DNC registry specifically, not to all telemarketing regulation.

How often do telemarketers need to update their Washington DNC scrub data?

At least every 31 days under FTC rules, which Washington effectively requires through alignment with the Telemarketing Sales Rule. Letting your suppression file age past that window is a compliance failure even if the original scrub was clean. Build the 31-day refresh into your campaign calendar as a fixed step, not an afterthought.

Can I be sued personally as a business owner or sales manager for Washington DNC violations?

Potentially, yes. Both the TCPA and Washington's Consumer Protection Act allow claims against individuals responsible for the violating calls, not only the corporate entity. If you personally directed a campaign that skipped list scrubbing, that creates individual exposure. Corporate liability alone is not a guaranteed shield, especially in small operations where ownership and operational control overlap.

Does the Washington do not call list apply to text messages?

Washington's statute addresses telephone solicitation calls, and mobile numbers are covered. For texts, the cleaner authority is the federal TCPA, which treats marketing text messages as calls and requires prior express written consent for automated texts to cell numbers. In practice, treat a Washington number on the DNC list as off-limits for both calls and unsolicited marketing texts.

How do I file a complaint about an unwanted telemarketing call in Washington?

File with the Washington UTC at utc.wa.gov and separately with the FTC at donotcall.gov. Include the date, time, the phone number that called you, the company name if stated, and a summary of what they said. Both agencies accept complaints and share data. The more detail you provide, the easier it is for regulators to investigate and act.

What is the Washington UTC's role in do not call enforcement?

The Washington Utilities and Transportation Commission administers the state DNC list under RCW 80.36.390. The UTC can investigate complaints, issue fines up to $1,000 per violation, and refer serious cases to the Attorney General for Consumer Protection Act enforcement. It also oversees telemarketer registration in Washington. It is the first regulatory contact for both consumers and telemarketers on state DNC matters.

If a customer gave me their number, do I still have to check the do not call list?

Yes, unless you have clear prior express written consent to call for marketing, or a documented EBR within the applicable window. Receiving a phone number on a form does not automatically authorize telemarketing calls. Consent must be specific, documented, and not buried in fine print the consumer could not reasonably have seen. When in doubt, get explicit written consent.

How does Washington's DNC law interact with the TCPA's autodialer rules?

They run in parallel. The TCPA governs the method of calling (autodialers, prerecorded messages) and requires prior express written consent for marketing calls to cell phones using those methods. Washington's DNC law governs whether you can call the number at all, regardless of equipment. You can break Washington's list rules with a manual dial, and you can break the TCPA even when the number is on no list.

Sources

1. Washington Utilities and Transportation Commission, Do Not Call Program: Washington UTC administers the state Do Not Call list under RCW 80.36.390; penalties up to $1,000 per violation
2. FTC, National Do Not Call Registry: Federal DNC Registry operated by FTC; telemarketers must update scrub data every 31 days; EBR windows of 18 months and 3 months
3. 47 U.S.C. § 227, Telephone Consumer Protection Act: TCPA sets $500 per violation, $1,500 trebled for willful; covers autodialers, prerecorded calls, text messages; national floor for telemarketing restrictions
4. Washington State Legislature, RCW 19.86.090, Consumer Protection Act: Washington CPA allows private plaintiffs actual damages trebled up to $25,000 per willful violation plus attorney fees
5. FTC, Telemarketing Sales Rule, 16 CFR Part 310: TSR sets EBR exemptions (18-month purchase, 3-month inquiry) and 31-day scrub cycle requirements for telemarketers
6. FCC, 47 CFR 64.1200, Rules Implementing the Telephone Consumer Protection Act: FCC rule requires prior express written consent for autodialed or prerecorded marketing calls to cell phones; EBR framework
7. Washington State Legislature, RCW 80.36.390, Telephone solicitation: Washington's state DNC statute; defines telephone solicitation, exemptions, $1,000 per violation penalty, UTC administration
8. FTC, Complying with the Telemarketing Sales Rule: FTC guidance on TSR compliance obligations for telemarketers including list access, scrubbing, and internal DNC requirements
9. Washington Office of the Attorney General, Consumer Protection: Washington AG has authority to pursue telemarketers under the Consumer Protection Act for DNC violations; can seek injunctive relief and civil penalties