TCPA Compliance Checklist That Helps Prevent Costly Dialer Mistakes in the New Year   

If your team runs outbound calls or texts, January is when dialer gaps appear quickly. New campaigns start. Sales pressure ramps up. Lists get uploaded. Someone changes a setting. Then the risk follows. This post is a TCPA Compliance Checklist you can run in January before the first campaign goes live. It is written for B2B teams doing real outreach.

TCPA lawsuit activity stayed hot in 2025. According to Eric Troutman, filings jumping 97% year over year. It also reported a heavy lean toward class actions. That matters because class actions scale fast when your volume is high.

The goal of this blog is simple. Catch problems early. Keep proof clean. Reduce the risk that a single bad list or dialer rule turns into a legal mess.

TCPA Compliance Checklist for January Dialer Readiness  

1) Confirm you can prove consent for each number  

Marketing calls and texts require valid consent. “We had permission” is not a defense if you cannot show it.

Run these checks:

• Consent record exists for each phone number you plan to contact
• Consent type matches the outreach type (calls, texts, prerecorded, automated)
• Timestamp is stored and easy to retrieve
• Source is stored (web form, inbound call, paper form, partner lead source)
• Language shown to the consumer is saved

Also, check how your system handles consent updates. A good record is not helpful if it is buried in a CRM note field that nobody can export.

2) Confirm revocation and opt-out rules work across every system  

Stop means stop. Opt-out should block future outreach across:

• The dialer
• The texting platform
• The CRM
• Any campaign tools used by sales reps

A common January failure is a split system. The texting platform honors “STOP.” The dialer still calls because the suppression list never got the update.

Run a quick test:

• Send a test opt-out keyword
• Confirm suppression hits all tools within minutes
• Confirm suppression applies to every campaign tag

3) Update National DNC and state DNC suppression  

DNC mistakes happen when teams assume the last scrub still counts.

Check these items:

• National DNC Registry scrubs are current
• State DNC rules are covered where required
• Internal DNC list is applied first, not last
• Suppression logic blocks both calls and texts when your policy requires it

Keep an audit trail. Save proof of the scrub date, the source, and the output logs.

4) Apply local time rules using the consumer’s time zone  

Calls must follow the allowed calling hours for the consumer’s local time. A dialer that uses the rep’s time zone or your server time can create violations at scale.

Do this in January:

• Confirm that the time zone lookup is based on the phone number or verified address
• Confirm daylight savings handling is correct
• Confirm the dialer blocks calls outside the allowed window
• Confirm state-specific quiet hours are enforced when applicable

5) Reassigned and wrong-party risk checks  

A lot of complaints start with one sentence: “That’s not me.”

Numbers change hands. People switch carriers. A record that was fine last year may be wrong today.

Run these checks:

• Reassigned number database checks for outbound lists
• Wireless vs landline flags are current
• Line status is checked when available
• Ported number indicators are monitored

Treat wrong-party reports as a high-signal event. One wrong-party complaint can point to a bigger list issue.

6) Clean duplicates and conflicting contact records  

Duplicates create mixed consent and mixed suppression. One record says “opted out.” Another record says “good to call.” The dialer follows the wrong one.

January cleanup tasks:

• Merge duplicate profiles tied to the same number
• Define one field as the source of truth for consent
• Define one field as the source of truth for DNC status
• Block dialing when fields conflict until reviewed

7) Review dialer modes and automation settings  

Dialers drift. Teams change settings to hit KPIs. Vendors push updates. Someone adds a new campaign mode.

Review:

• Preview, power, predictive, and any automated dialing settings
• Recorded message settings
• Drop call handling and abandonment controls
• Call frequency limits per number per day
• Retry logic for busy, no answer, failed calls

Document what each mode does and the consent level required for each.

8) Confirm caller ID and identification rules are followed  

Your outbound identity needs to be clear. That means:

• Accurate caller ID where required
• Clear business name in scripts and messages
• A working callback number when required
• A process for call-back handling and opt-out requests

Store the script version used during each campaign. If language changes mid-month, keep both versions.

9) Make lead source rules real, not theoretical  

Buying leads creates two problems fast:

• Consent proof is weak or missing
• Consent language does not match what you actually send

Ask vendors for:

• TCPA compliance tools they use to verify data or leads
• The consent language shown to the consumer
• The date and time captured
• The method used to capture it
• Proof the consumer agreed to be contacted at that number
• A record format you can store and retrieve quickly

If the vendor cannot provide that, treat the list as high risk. Do not “clean it later.” January is not the time to gamble.

One more 2025 reality check for leadership about TCPA Compliance

The risk of court interpretation increased in 2025. A U.S. Supreme Court decision in McLaughlin Chiropractic Associates v. McKesson changed how district courts approach FCC TCPA interpretations in litigation. The short version is that relying solely on FCC guidance became less predictable across courts.

That uncertainty matters for dialer programs because legal exposure often comes down to how a court views the scope of consent, opt-out handling, and what counts as covered contact activity.

Compliance teams cannot control the courts. Your team can control your records, your suppression logic, and your dialer settings.

TCPA Compliance risk: Dialer vendor responsibility and outsourcing

Outsourcing does not outsource liability. That includes third-party call centers, lead gen shops, and vendors who run campaigns “for you.”

January is the right time to tighten vendor controls because new contracts and new budgets kick in early in the year.

Add these steps to your TCPA Compliance Checklist:

• Require vendors to follow your suppression lists, not their own
• Require written confirmation of scrub cadence and data sources
• Require access to dial logs and message logs within 24 hours of request
• Require proof of opt-out handling across every channel
• Require a rule that vendors stop dialing a number after a wrong-party report until reviewed

State enforcement also stayed active in 2025. Multi-state efforts targeted providers and intermediaries tied to illegal robocall traffic. That trend is a reminder that “upstream” and “downstream” partners can become part of the story when regulators and investigators follow call paths.

Keep vendor oversight simple. If a vendor cannot show you what they did, when they did it, and how they applied your rules, that is a risk signal that could lead to vicarious liability.

Logs and reporting that hold up under pressure  

10) Keep dial logs that answer hard questions fast  

Your logs should answer these questions without manual work:

• Who was called or texted
• What number was used
• What campaign was running
• What message or script version was used
• What consent record supported it
• What time zone logic was applied
• What suppression checks were applied
• What happened after contact (answer, voicemail, opt-out, complaint)

11) Preserve opt-out records long-term  

Opt-out history needs to survive:

• CRM migrations
• Vendor changes
• Dialer replacements
• Data cleanups

If you rebuild your systems in Q1, make opt-outs a protected dataset that never gets overwritten.

Test and monitor before launch  

12) Run mock audits before high-volume campaigns  

Run a small test batch and review results like an auditor would.

Look for:

• Calls placed outside allowed hours
• Suppressed numbers dialed due to sync delays
• Records missing consent fields
• Reassigned number flags ignored
• Duplicate records overriding suppression

13) Treat early warning signals as action items  

Watch for:

• Spike in “wrong number” complaints
• Sudden increase in opt-outs
• Carrier labeling and call blocking patterns
• Agent notes that repeat the same complaint theme

Patterns usually show up before legal letters do.

Why reviewing TCPA compliance process matters now  

TCPA enforcement pressure in 2025 also showed up in regulator activity tied to illegal call traffic networks. The FCC continued enforcement actions and proposed major penalties in robocall-related matters. One example reported a proposed $4.49 million fine tied to alleged robocall activity routed through a provider.

Even if your program is lawful, your records need to prove it. That is the part teams regret skipping.

What leadership should ask in the January TCPA Compliance review  

Use these TCPA Compliance questions to run a clean meeting and get real answers.

Are we dialing only numbers with proof we can produce quickly?
If the answer depends on a vendor email thread, that is not a strong position.

Do opt-outs stop future outreach everywhere?
One missed sync can undo months of careful work.

Do our time zone rules always follow the consumer’s local time?
Confirm it with real test cases across states.

Are we checking the reassigned number risk before launch?
Wrong-party complaints are not random. They often trace back to process gaps.

Do we know exactly what our vendors are doing in our name?
If you cannot audit it, you cannot defend it.

January sets the tone for Q1. Dialer readiness is not paperwork. It is the guardrail that keeps growth from turning into a costly distraction.

Key Takeaway  

January is not just a fresh start for campaigns. It is the point where small dialer issues either get fixed quietly or turn into problems that follow your team all year.

This TCPA Compliance Checklist is not about slowing growth or adding red tape. It is about making sure your outreach engine runs on data you can defend. Clean consent records. Reliable opt-outs. Accurate time zone logic. Vendors that follow your rules, not theirs. Logs that answer questions without panic.

Run this checklist before the first campaign goes live. Revisit it when systems change. Make it part of how your team operates, not something pulled out only after a problem shows up.

That approach does not eliminate risk. It keeps risk from turning into a distraction that costs time, money, and focus when you should be building momentum.

SHAMELESS PLUG: Register for Searchbug’s API Test Account today to try our TCPA Compliance tools for free!