Australia has four Do Not Call Register washing channels and only two of them can be driven by a machine: Secure File Transfer Protocol and Simple Object Access Protocol. Washing is paid for in credits under a fee schedule the ACMA approved on 27 September 2021, still published on 10 September 2026, running from 500 credits free to 100,000,000 credits for A$142,271.
The law is the easy part, and we have already written it: our guide to the Do Not Call Register rules for AI voice agents and how the ACMA enforces them covers the synthetic-voice definition in the Do Not Call Register Act 2006 (Cth), the section 11(3) thirty-day safe harbour, the calling hours in the Telecommunications (Telemarketing and Research Calls) Industry Standard 2017, and two Federal Court and ACMA enforcement actions. What that page does not do is tell you how the wash physically happens. This one does: the submission channels, the file format the register will reject, what credits cost per number, and the three places an always-on agent silently loses the safe harbour it thinks it has.
The reason it matters more for an autonomous agent than for a call centre is that “washed within 30 days” was written for people who download a list on Monday and burn it by Friday. An agent dials continuously against a database that keeps growing. The wash stops being a pre-campaign chore and becomes a scheduler invariant. The equivalent problem in the United States, with different numbers and a per-area-code subscription, is in our guide to scrubbing a calling list against the US National Do Not Call Registry.
How do I wash my calling list against the Do Not Call Register automatically?
Through one of two channels, and the register is unusually direct about the trade-off. Its washing process overview publishes a four-column comparison of the channels, reproduced below with its own wording for the skills column. All four charge the same rate; what differs is who can drive them.
| Channel | Transport | Opportunity to abort after pre-wash | Receipt | Technical skills required (register’s own wording) |
|---|---|---|---|---|
| Website | HTTP-web upload | Yes | Available after each transaction | Mid-level: able to use spreadsheets |
| Quick wash | HTTP-web upload | No | Available after each transaction | Low-level: no special skills |
| Automated washing service | Secure File Transfer Protocol (SFTP) | No | Available after each transaction | High level: programming skills |
| Real time access | Simple Object Access Protocol (SOAP) | No | Option for daily summary email available, sent at midnight each day | High level: programming skills |
Read that table as an engineer and the shape of the problem appears immediately: the only channel that lets you cancel a submission after the register has found errors in it is the one channel a nightly job cannot use. Everything below follows from that sentence.
Two smaller facts worth carrying. The register’s washing steps page says washing “will generally take from a few seconds to one minute, depending on the size of the contact list, the washing channel used, the load on the register’s system at that time and the preferred format for the returned washed list” — so a wash is not a batch window you have to plan a night around. And for genuinely small checks, the register’s Industry FAQs state that businesses wanting to wash fewer than 10 numbers “can do so immediately by using the Quick check facility”.
What washing actually costs: the ACMA fee table, and the cost per number
Subscriptions are sold as blocks of wash credits, one credit per number submitted. The eight tiers below are the schedule served on the register’s subscription overview page, read 10 September 2026; the register notes that these fees “were approved by the ACMA on 27 September 2021 and came into effect on 1 October 2021”. The right-hand column is ours — the register publishes the tiers but not the unit cost, and the unit cost is the number that decides how you build.
| Subscription type | Wash credits | Fee | Cost per number washed (our calculation) |
|---|---|---|---|
| A | 500 | A$0 | Free, capped at 500 numbers per annum |
| B | 20,000 | A$126 | 0.630 cents |
| C | 100,000 | A$585 | 0.585 cents |
| D | 1,000,000 | A$5,058 | 0.506 cents |
| E | 10,000,000 | A$42,682 | 0.427 cents |
| F | 20,000,000 | A$71,136 | 0.356 cents |
| G | 50,000,000 | A$106,703 | 0.213 cents |
| H | 100,000,000 | A$142,271 | 0.142 cents |
Three things fall out of that column that the tier list alone hides.
- The discount is almost flat until you are very large. Going from Type C to Type D buys ten times the credits for a 13.5% cut in unit price. Going from Type F to Type G cuts it by 40%. The volume discount is back-loaded.
- Stacking cheap tiers beats buying an expensive one, up to a crossover we can name. The register states plainly that you can hold several subscriptions, and that your account “will display a single number of wash credits showing how many numbers are left under your subscriptions collectively”. Nine Type D subscriptions cost A$45,522 for nine million credits; one Type E costs A$42,682 for ten million. The crossover sits at about 8.4 million credits a year — below that, stacking Type D is cheaper than Type E; above it, buy the E. The same arithmetic puts the C-to-D crossover at about 865,000 credits.
- The free tier is a trap if you are not careful with it. Type A is 500 credits at no charge, but you “may only hold one subscription Type A at a time”, and if you buy any other subscription type “your subscription Type A will be automatically cancelled and any remaining wash credits will be forfeited”. Spend the free 500 on format testing before you buy, not after.
Two subscription mechanics belong in your renewal calendar rather than your codebase. Subscriptions run 12 months from the date of purchase; unused credits roll into a new subscription only if you buy the new one before the old one expires, and are otherwise forfeited. And credit card payments are capped at A$30,000, which quietly rules the card out for Types E and above.
Wash the queue, not the list: the calculation that decides your bill
Here is the rule, and it is the one thing on this page worth stealing: wash credits are charged per number submitted, not per number stored, so wash the numbers you are about to dial rather than the database that holds them. For a continuously dialling agent that is simultaneously cheaper and fresher, which is a rare combination in compliance engineering.
Worked end to end, with inputs you can substitute. Take an Australian outbound agent with 100,000 numbers in the CRM, placing 2,000 dial attempts per working day across 260 working days, which is 520,000 attempts a year — each record attempted about five times. Every dialled number must carry a wash result less than 30 days old.
| Wash strategy | Credits consumed per year | Cheapest cover from the fee table | Worst-case wash age at dial time |
|---|---|---|---|
| Whole database, monthly | 100,000 × 12 = 1,200,000 | 1 × Type D + 2 × Type C = A$6,228 | 30 days — no failure budget at all |
| Whole database, fortnightly | 100,000 × 26 = 2,600,000 | 2 × Type D + 6 × Type C = A$13,626 | 14 days |
| Tomorrow’s dialling queue, nightly | 520,000 | 5 × Type C + 1 × Type B = A$3,051 | 1 day |
The nightly queue wash costs under a quarter of the fortnightly whole-database wash — A$3,051 against A$13,626, a saving of about 78% — and lands wash results fourteen times fresher. Each cover in that column applies the stacking arithmetic above: one Type D for each whole million credits, then Type C and Type B for the remainder, because every remainder here falls below the 865,000-credit C-to-D crossover. Buying one tier per row instead would cost A$5,058 for the nightly queue and A$10,116 for the monthly whole-database wash: about 66% and 62% more for exactly the same credits.
The threshold, so you know when the rule stops paying. Queue washing wins whenever your annual dial attempts are fewer than your database size multiplied by your whole-list cadence. In this example that crossover is 1,200,000 attempts a year, or about 4,615 attempts per working day. An agent dialling harder than that is touching every record more often than a monthly wash would, and should simply wash the list. Below it, wash the queue. We have not seen an outbound deployment anywhere near the crossover, but the arithmetic is the arithmetic and you should run it on your own numbers.
Invalid numbers still consume credits — and come back undialable
This is the failure that costs real money and real safe harbour, and it is stated flatly on the register’s washing steps page: numbers that do not satisfy the format criteria “will be considered invalid and will not be washed. However, invalid numbers will be counted as submitted numbers against an account-holder’s subscription.”
Charging for the bad rows is the smaller half of the problem. The larger half is what comes back. One of the return formats is the submitted list with an indicator against each row — the register’s example is “Y = Yes, this number is on the register; or N = No, this number is not on the register; or I = Invalid, this number is invalid”. A pipeline written the obvious way filters out the Y rows and dials the rest. That pipeline dials every I row, and an I row was never washed.
So the second rule on this page, and the one to hand an engineer: dial the N rows, not the not-Y rows. Anything that is not an explicit N — a Y, an I, or a submitted number that never came back at all — is not a wash result, and an unwashed number is not a clear number. Fail closed, per row, at dial time. That is the same evidentiary logic we set out in our note on compliance architecture for AI sales agents in regulated industries: the log is the control.
Because SFTP and SOAP give you no opportunity to abort after the pre-wash, you have to build the register’s own error check into your exporter. These are its published constraints, condensed on the left with the CRM habit that breaks each one on the right; anything in quotation marks is the register’s own wording.
| What the register requires | Where a CRM export breaks it |
|---|---|
| Between three and seven digits, or exactly 10 digits including the area code but not the country code, or 11 digits if commencing with +61 or 61 | Numbers normalised to E.164 without the plus, giving a 61-prefixed 11-digit string that passes, next to legacy rows that do not |
| Must commence with a zero or a one. The register lists this alongside the 11-digit +61 and 61 forms without reconciling the two, so validate against the whole criteria set rather than one bullet | Excel dropping the leading zero. The register’s Industry FAQs document this exact failure on export and give the Text-column import workaround |
| Commas are not allowed; a comma inside a number is replaced with the text string {COMMA} before the row is marked invalid | Trailing commas emitted by a CSV writer at end of line |
| A single column of numbers only, with no other data or data fields, blank cells or hidden characters | Exporting the contact record instead of the number column, taking customer IDs and names along with it |
| CSV, .txt or .dat, no larger than 10 MB compressed (except for the AWS/SFTP channel — AWS here is the register’s Automated Washing Service, not Amazon Web Services) | Whole-database washes pushed through the web channel — another reason the queue is the better unit |
| File name limited to A-Z, 0-9 and underscores, with no spaces | Date-stamped file names written with spaces or colons |
| A new file each time, because “remaining remnants of the old file (even though deleted) will cause errors” | Appending to a reused template file |
Multi-factor authentication changed which channels a machine can drive
This is the newest thing on this page and the one most likely to break an existing integration. The register’s Industry MFA Upgrade page, read 10 September 2026, says the ACMA “will shortly introduce multi-factor authentication (MFA) to the Do Not Call Register”, while its Industry FAQs already answer the question “Is MFA compulsory for DNCR access?” with “Yes, all account holders are required to use MFA to use the Do Not Call Register service.” Both Admin and Wash Only accounts are in scope, passphrases must be at least 16 characters, and sign-in requires a six-digit code from an authenticator app on a smartphone. Get the sign-in wrong repeatedly and, in the register’s words, “your account will be locked for 24 hours”.
Now the part that matters architecturally. The register states that the SOAP service “does not require MFA” — you only have to update the passphrase your SOAP client sends to match the new one — and that access to automated washing over SFTP “will not be impacted by MFA”. So the two channels rated “High level: programming skills” are the two that survive contact with an unattended job, and the two rated low and mid-level are being gated behind an interactive second factor. (The register does publish a fallback: a one-time code sent to the registered email address, plus a single-use recovery code issued at setup. Neither belongs in a cron job.) A 24-hour account lockout is also longer than a nightly wash cycle, which means a human-driven fallback is not a fallback at all.
If your current process is a person logging in and uploading a spreadsheet, MFA has just made that person a single point of failure with a 24-hour blast radius. That is the honest trigger for moving to SFTP or SOAP, and it is a better reason than cost.
Does the Do Not Call Register cover SMS? No, and that mistake is expensive
It covers telemarketing calls and marketing faxes. The register’s own About page describes it as “a secure database where individuals and organisations can register, check or remove their Australian telephone, mobile and fax numbers to opt out of receiving most unsolicited telemarketing calls and faxes”. Mobile numbers are registrable, which is where the confusion starts — but what a registration blocks is a marketing call to that mobile, not a marketing text message to it. The register answers this directly on its FAQs for consumers page, read 10 September 2026, under the question “Will registering my number stop me from receiving SMS Marketing?” The answer is “No, registering your mobile number will not prevent you from receiving SMS marketing”, and the next line is “SMS marketing is covered by the Spam Act 2003”.
Marketing SMS sits under the Spam Act 2003 instead, administered by the same regulator under an entirely different set of duties. The ACMA’s guidance on avoiding sending spam sets them out: consent before sending, accurate identification of the sender with contact details that must “remain correct for at least 30 days after you send the message”, and an unsubscribe that honours a request “within 5 working days” and stays “functional for at least 30 days after you sent the message”. None of that is a wash, and no number of wash credits buys it. Our post on inferred consent under the Spam Act for AI agents covers where that consent can and cannot be inferred, and the SMS Sender ID Register covers the sender side.
Scoping the negative honestly, because it is the kind of claim that deserves it: across the seven donotcall.gov.au pages an industry account holder would actually read — washing process overview, washing steps, subscription overview, industry overview, Industry FAQs, Industry MFA Upgrade and consumer overview, all read 10 September 2026 — the strings “SMS” and “text message” do not appear once. Every duty on those seven pages is framed as a call or a fax. The register does address SMS, but only on the consumer FAQ quoted above; nothing on the industry side of the site tells a telemarketer that washing a list buys them nothing for a text message.
Your washed file disappears on day 30, and so does your evidence
The register keeps the output for exactly as long as the output is useful. Its washing history section states that washed files “are available for download for up to 30 days” — the same length as the window in which a wash result protects a call. On day 31 you have neither a current wash nor a copy of the file that produced it.
That is why step 6 of the washing process matters more than it looks. At the end of each wash the account holder is emailed a receipt containing, in the register’s words, “a unique list-washing transaction ID, details of your current subscription balance and details of the washing transaction performed”. Pull that transaction ID into your own store, attach it to every call detail record the wash cleared, and archive the returned file yourself. The register’s Industry FAQs describe the defence you are evidencing: “If the marketer has washed its list against the register during the 30 days prior to the call or fax, and the register did not state that the number contacted was on the list, then the marketer will not be in breach of the legislation.” Note who has to be able to prove it.
The adjacent relief is narrower than it sounds. The same FAQ set says a telemarketer who calls a registered number “will not be liable for any penalty if they can satisfy the ACMA that the call was made/fax was sent by mistake” — a defence conditioned on satisfying the regulator, which is an evidentiary burden, not a shrug. The register also publishes a line for washing errors: it directs account holders to call the register operator on 1300 785 749 for information on list-washing reversals.
What this costs to run, honestly
Everything above is buildable in-house and we have deliberately given you enough to do it. What it actually costs is a small service rather than a script: an SFTP or SOAP client with credentials that survive the MFA rollout, a pre-wash validator that reimplements the seven format rules the register only checks interactively, a nightly job with retry and alerting, a dial-time gate that refuses any number without an N result under 30 days old, and an archive of transaction IDs joined to call records. Plus the renewal calendar, because credits expire in 12 months and a lapsed subscription stops the dialler, not just the wash.
The honest crossover: below roughly 20,000 numbers a year, dialled in discrete campaigns rather than continuously, do this by hand on the website channel. The abort-after-pre-wash is free error checking, a Type B subscription is A$126, and building the automation would cost more than the credits. Above that, or the moment the dialling becomes continuous, the manual path stops being viable — not because of the credits, but because a rolling 30-day window has no natural place for a human to stand.
Zian’s outbound agents are built so that wash age and suppression state are checked in the platform layer at dial time rather than at list-build time, for the reason set out above: with a continuously dialling agent there is no campaign boundary to hang a wash on. Zian AI is in a partnership-application beta, with no free trial and no self-serve signup. If you are evaluating any AI calling vendor for the Australian market, us included, the useful question is not whether they support the Do Not Call Register — it is which of the four channels they submit through, what they do with an I row, and whether they can show you the list-washing transaction ID attached to an individual call record. More on how the platform is put together is on our solutions page.
Do Not Call Register washing: frequently asked questions
How often does an AI dialler have to re-wash a list against the Do Not Call Register?
Every dialled number needs a wash result obtained inside the 30 day period ending on the day the call is made, so a continuously dialling agent needs a rolling cadence rather than a pre-campaign wash. Because wash credits are charged per number submitted and not per number stored, washing the queue for the next night of dialling is usually both cheaper and fresher than washing the whole database once a month. The Do Not Call Register sets out the washing steps at donotcall.gov.au, read on 10 September 2026.
How much does it cost to wash numbers against the Do Not Call Register?
There are eight subscription types. Type A gives 500 wash credits a year at no charge. The paid tiers run from Type B at 20,000 credits for A$126 to Type H at 100,000,000 credits for A$142,271. The Australian Communications and Media Authority approved that schedule on 27 September 2021 and it came into effect on 1 October 2021. It was still the published schedule on 10 September 2026. These are government access fees and they are not the cost of any AI calling platform.
Can I wash numbers against the Do Not Call Register through an API?
Yes, through two channels. The Automated Washing Service submits files over Secure File Transfer Protocol, and Real Time Access is a Simple Object Access Protocol service. The Do Not Call Register rates both as requiring high level programming skills. The two web channels, website upload and Quick wash, are interactive HTTP uploads and sit behind the multi factor authentication the register is rolling out, which is why they cannot be driven by an unattended job.
Do invalid numbers use up wash credits?
Yes. The washing steps page states that numbers which do not satisfy the format criteria are considered invalid and will not be washed, but that invalid numbers are counted as submitted numbers against the subscription of the account holder. Only the website upload channel offers an opportunity to abort after the pre wash error check, so anyone submitting over SFTP or SOAP has to validate the file before it leaves their own systems.
Does the Do Not Call Register cover SMS marketing?
No. The register covers telemarketing calls and marketing faxes. A mobile number can be listed on the register, but the listing stops marketing calls to that mobile rather than marketing text messages. Marketing SMS is governed instead by the Spam Act 2003, which the Australian Communications and Media Authority administers with its own duties on consent, sender identification and unsubscribe. The register says so itself on its FAQs for consumers page, read 10 September 2026: registering your mobile number will not prevent you from receiving SMS marketing, because SMS marketing is covered by the Spam Act 2003.
How long can I download a washed file for?
Up to 30 days. The washing history section of the washing steps page states that washed files are available for download for up to 30 days, which is the same length as the window in which the wash result is useful. On day 31 you have neither a current wash nor a copy of the file that produced it, unless you archived the returned file and the list washing transaction identifier from the emailed receipt into your own records.
Sources and verification
| Figure or claim | Owner | Verified at |
|---|---|---|
| Four washing channels; abort-after-pre-wash available on the website channel only; SFTP and SOAP rated high level programming skills; RTA daily summary email sent at midnight; all channels charged at the same rate | ACMA, Do Not Call Register | donotcall.gov.au/industry/washing-process-overview (read 10 September 2026) |
| Number and file format rules; invalid numbers counted against the subscription; pre-wash error checking; return formats including the Y/N/I indicator file; turnaround of a few seconds to one minute; washing receipt contents; washed files downloadable for up to 30 days | ACMA, Do Not Call Register | donotcall.gov.au/industry/washing-process-overview/washing-steps (read 10 September 2026) |
| Eight subscription tiers and fees A$0 to A$142,271; fees approved by the ACMA on 27 September 2021, effective 1 October 2021; 12-month validity and credit forfeiture; Type A single-holding and auto-cancellation rules; multiple subscriptions pooled into one credit balance; credit card payments limited to A$30,000 | ACMA, Do Not Call Register | donotcall.gov.au/industry/subscription-overview (read 10 September 2026) |
| MFA compulsory for all account holders; 16-character passphrase minimum; 24-hour lockout after repeated failed sign-ins; SOAP does not require MFA; SFTP access not impacted; Quick check facility for fewer than 10 numbers; free Type A limited to 500 numbers per annum; list-washing reversals line 1300 785 749; the 30-day wash defence | ACMA, Do Not Call Register | Industry FAQs and Industry MFA Upgrade (both read 10 September 2026) |
| Register scope stated as Australian telephone, mobile and fax numbers opting out of unsolicited telemarketing calls and faxes; registration does not stop SMS marketing, which is covered by the Spam Act 2003 | ACMA, Do Not Call Register | About the Do Not Call Register and FAQs for consumers (both read 10 September 2026) |
| Marketing SMS governed by the Spam Act 2003; consent, sender identification correct for at least 30 days, unsubscribe honoured within 5 working days and functional for at least 30 days | Australian Communications and Media Authority | acma.gov.au/avoid-sending-spam (read 10 September 2026) |
| Cost per number washed; the 8.4 million credit Type D to Type E crossover; the 865,000 credit Type C to Type D crossover; the three-strategy wash cost comparison; the 4,615 attempts per working day queue-wash threshold | Zian AI (our calculation from the ACMA fee table above) | Arithmetic shown in full on this page; inputs are the published tiers and the stated example volumes |