The short answer
The UK's TPS, the US National Do Not Call Registry and Australia's Do Not Call Register all do the same basic job: a person lists a number, and marketing calls to it become unlawful. They differ on who can register (the UK lets companies in through CTPS; the US takes personal numbers only, and Australia private numbers plus fax-only and government lines), on how fresh your check must be, and on what they exempt. The UK has no exemption for business-to-business calls to a registered number, while the US exempts most of them and Australia does not let business phone numbers onto the register.
This is a plain-English summary of three sets of rules, not legal advice.
The three registers side by side
| UK: TPS and CTPS | US: National Do Not Call Registry | Australia: Do Not Call Register | |
|---|---|---|---|
| Law | PECR 2003, regs 21 and 26 | FTC Telemarketing Sales Rule (and FCC rules) | Do Not Call Register Act 2006 |
| Who can register | Individuals (TPS) and companies (CTPS) | Personal numbers only | Private or domestic numbers, fax-only numbers, government-only numbers |
| Business numbers | Yes, through CTPS | Not covered | Not eligible (fax lines aside) |
| Mobiles | Yes | Yes, treated like home phones | Yes, if used mainly for private purposes |
| How long a registration lasts | Until the number stops being the subscriber's; CTPS gets a yearly reminder | Never expires | Indefinitely, until removed |
| The day count | A new registration binds callers after 28 days | Scrub your list at least every 31 days | A wash protects you for 30 days |
| How callers get access | Licensed list cleaners; DMA royalty of 10p per 1,000 records | FTC subscription; 5 area codes free, then $85 each a year | ACMA subscription; 500 washes free, then paid tiers |
| B2B sales calls | Covered (CTPS) | Mostly exempt | Business numbers cannot be listed |
| Charities and political calls | No exemption in reg 21 | Not covered | Exempt (designated calls) |
| Maximum penalty | £17.5 million or 4% of global turnover | Up to $53,088 per violation | 100 penalty units per call for a company (500 with a prior record) |
Who can register, and what is covered
UK. Regulation 26 of PECR sets up one register of numbers whose subscribers have said they do not want unsolicited marketing calls. It takes both individual and corporate subscribers; corporate notifications must be in writing, and the register keeper sends each company a written reminder every year. In practice that one register is run as two files, TPS for consumers and CTPS for companies, which is why a B2B team in the UK has to check both (I explain the split in TPS vs CTPS). Nothing in the regulation limits it to landlines, and mobiles sit on TPS like any other number; see does TPS cover mobile numbers.
US. The FTC is blunt: "The Registry is for personal phone numbers. Business phone numbers and fax lines are not covered." Mobiles are in: "There’s no difference between cell phone and home phone numbers once they’re listed." A registration "will never expire", unless the number is disconnected and reassigned or the owner removes it.
Australia. Section 14 of the Act makes a number eligible if it is used or maintained primarily for private or domestic purposes, used only for faxes, or used only by a government body. The register's own consumer page says "Business telephone numbers are not eligible for registration", and a number "will remain on the register indefinitely unless you actively remove it."
The 28, 31 and 30 days are not the same rule
- UK, 28 days, counted from registration. Regulation 21(3) says a caller has not broken the rule where the number "has been listed on the register for less than 28 days preceding that on which the call is made." It is a grace period on the register side, and it says nothing about how often you must check. I cover the two different UK 28-day rules in the 28-day TPS rule.
- US, 31 days, counted from your scrub. The FTC requires sellers and telemarketers to "synchronize your lists with an updated version of the registry at least every 31 days."
- Australia, 30 days, counted from your wash. Section 11(3) of the Act protects a caller whose list was washed and came back clear during the 30-day period ending on the day of the call. The register puts it as "In general you can rely on the washed list for 30 days." The protection covers a list "submitted by the person" who makes the call. Anyone else, such as a business relying on a wash someone else ran, may have to rely instead on section 11(5): reasonable precautions and due diligence.
So a UK caller is protected for 28 days after someone registers, whatever their own cadence, while a US or Australian caller is protected only if their own check is no older than 31 or 30 days.
How callers get the data, and what it costs
UK. PECR lets callers get the register's data on payment of a fee, and lets the operator hand the job to someone else. In practice you screen through a list cleaner licensed by the DMA, which runs TPS and CTPS. Since 1 September 2026 the DMA charges a royalty of 10p per 1,000 records processed, capped at £3,300 per client per year; callers who hold their own licence are exempt. How screening and suppression fit together is in TPS and CTPS suppression explained.
US. Callers buy access by area code. Data for up to five area codes is free; from 1 October 2026 the annual fee is $85 per area code after that, capped at $23,425 a year for the whole country. Each subscription runs twelve months and comes with a Subscription Account Number (SAN) that expires with it.
Australia. Callers buy wash credits from ACMA. There are eight subscription types: Type A gives 500 washes free, Type B 20,000 for $126, Type C 100,000 for $585, Type D 1,000,000 for $5,058, up to Type H at 100 million. Subscriptions last 12 months from purchase, and every number sent uses a wash.
Exemptions: charities, politics and B2B
UK. Regulation 21 applies to any unsolicited call for direct marketing purposes, and its text contains no exemption for charities, political parties or business-to-business calls. The exception that does exist is consent: a subscriber on the register can tell a particular caller they do not object to its calls, and can withdraw that at any time (regulation 21(4) and (5)).
US. The FTC rules "do not cover calls from political organizations, charities", and most calls to a business to sell to that business are exempt. Debt collection, purely informational and survey calls are allowed if they carry no sales pitch. A company with an established business relationship may call for up to 18 months after the consumer's last purchase or delivery, and for three months after an inquiry.
Australia. Schedule 1 of the Act lists designated telemarketing calls that may go to registered numbers: calls authorised by government bodies and registered charities (if the call is about goods or services, the body must be the supplier), registered political parties and candidates, and educational institutions, each within conditions the Schedule sets. Consent also lifts the ban. It can be express or reasonably inferred, and express consent given without a stated period lapses after three months.
Penalties
UK. Since 5 February 2026 the ICO can fine up to £17.5 million or 4% of global annual turnover for a PECR breach.
US. The FTC says violators "may be subject to fines of up to $53,088 per violation" and that "each call may be considered a separate violation." The registry is enforced by the FTC, the FCC and state officials.
Australia. ACMA enforces the Act. Section 25 caps the civil penalty for a call to a registered number at 100 penalty units per contravention for a company with no prior record, and 2,000 penalty units for all contraventions on one day. With a prior record the caps rise to 500 and 10,000 penalty units. The dollar value of a penalty unit is set separately under Commonwealth law.
Teams calling more than one country
If one team dials into two or three of these countries, the register to check is set by the number you are calling, not by where your office is.
- Route each number by country code. A +44 number gets a TPS and CTPS check, a +1 number a Do Not Call Registry check, a +61 number a DNCR wash. A UK check on an Australian number tells you nothing.
- Run the strictest cadence everywhere. The US needs a scrub no older than 31 days and Australia a wash no older than 30. A single 28-day cycle meets both.
- Do not carry B2B habits across borders. A US team used to calling businesses freely will breach PECR the first time it dials a UK direct line on CTPS.
- Keep one internal do-not-call list across all three. In the UK a person who has told you to stop is off limits under regulation 21(1)(a), and in the US a company-specific do-not-call request binds you, whether or not the number is on the national register.
TPSClear washes Australian numbers against the Do Not Call Register as well as screening UK numbers against TPS and CTPS; the Australian plans are on the Australian pricing page. For the UK rules in full, see TPS and PECR compliance.
Summary
The UK covers companies as well as people and gives callers 28 days after a new registration; the US covers personal numbers only, exempts most B2B calls and wants a scrub every 31 days; Australia covers private numbers, exempts charities, political parties and educational institutions, and protects your own wash for 30 days.