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TPS and CTPS Screening for B2B Cold Calling in the UK

The practical guide to Telephone Preference Service rules for business calling: TPS vs CTPS, PECR consent and opt-out duties, Ofcom dialler expectations, screening suppliers, and a pre-campaign checklist.

Ringby Team

Cold calling is legal in the UK. Cold calling sloppily is where the fines live. This guide covers the rules that actually apply to B2B outbound teams: the two suppression registers, the consent and opt-out duties, the dialler expectations, how screening works operationally, and what evidence to keep. It is practical guidance from people who build dialling software, not legal advice. If you are unsure about a specific campaign, ask your solicitor before the ICO asks you first.

TPS vs CTPS: check both, every time

Two registers, one job: opting out of live direct marketing calls.

  • TPS (Telephone Preference Service): individuals, sole traders and most partnerships. The register most buyers have heard of.
  • CTPS (Corporate Telephone Preference Service): limited companies, LLPs, partnerships in Scotland, government bodies and other corporate subscribers.

B2B teams get this wrong constantly, because a bought list labelled "companies" contains sole traders, and a list labelled "directors" contains personal numbers. Screen every number against both registers. A number on either list is a hard stop unless that specific subscriber has notified you that they consent to your calls. Note the standard: not a generic opt-in, not a prior business relationship, not a LinkedIn connection. Specific, informed, freely given consent to your marketing calls, evidenced in writing.

PECR: the three standing duties

The Privacy and Electronic Communications Regulations govern the call itself, over and above screening:

1. Honour your own opt-outs, permanently. Anyone who objects to your calls, by any channel, goes on your do-not-call list forever, checked before every campaign, across every list and every rep. This is the first list regulators ask for in an investigation, and "the rep forgot" is not a defence. Your dialler should enforce suppression automatically at serve time, not rely on humans remembering.

2. Identify yourself and present CLI. State who is calling and on whose behalf, and never withhold your number on marketing calls. Beyond compliance, withheld numbers crater answer rates, so this one pays for itself.

3. Automated calls need prior consent, always. Recorded-message marketing calls, AI voice agents dialling out, press-1 campaigns: all require explicit prior consent, with very narrow exceptions. Human reps dialling live do not need prior consent (screening plus no-objection suffices). This asymmetry is structural, not a loophole to engineer around, and it is one reason serious UK outbound teams keep humans on the dial while reserving automation for answering and follow-up. Our comparison of predictive versus power dialling covers the dialler half of this.

Ofcom and your dialler choice

Separate from PECR, Ofcom polices what automated dialling equipment does to the network. Abandoned calls (answered by a live person, no agent available) and silent calls are treated as persistent misuse, with penalties up to £2 million. The standing expectations:

  • Abandon rate under 3% of live calls, per campaign, per 24 hours, including a reasoned estimate of answer-machine false positives
  • A brief recorded information message within 2 seconds of an abandoned answer, naming the company with a freephone or basic-rate contact number and no marketing content
  • CLI on every call, 72-hour re-dial lock on abandoned numbers, 15-second minimum ring on unanswered calls

A sequential power dialler with a human on every call generates no abandoned calls by construction. Technology choice is compliance strategy, and it is the cheapest compliance strategy available: roughly £49 a seat versus a compliance function.

How screening works operationally

The TPS and CTPS registers are operated on Ofcom's behalf; businesses screen through licensed suppression-file suppliers, typically as a list-wash service (upload list, get back screened list plus a certificate) or an API for high-volume operations. What matters for a small team:

  • Screen before first use, every list, no exceptions. New purchase, new scrape, new event list, new partner data: wash first, dial second.
  • Re-screen on cadence. Monthly is the common standard. Registrations change daily, and a list screened in January is evidence of nothing by June.
  • Keep the certificates. Dated screening evidence per list per campaign, filed where you can produce it in 24 hours. In an investigation, documentation is the difference between a warning and a fine.
  • Screening is necessary, not sufficient. It covers the registers. Your own opt-outs, consent records and the PECR duties above are separate obligations.

Costs are trivial at small-team scale (list washing runs to pounds per thousand numbers through most suppliers), which is worth stating plainly: there is no budget argument against compliance here, only an organisation argument.

Sector notes worth knowing

Legal, financial services and claims-adjacent work attract disproportionate complaint volumes, because recipients complain to sector regulators (SRA, FCA) who refer onwards. If you call in these sectors, hold yourself to a higher standard than the minimums: tighter screening cadence, recorded consent where you rely on it, and call recording with notice as standard practice.

Recruitment calling candidates about roles is generally not direct marketing (it is not promoting goods or services to them in the PECR sense), but calling clients to sell recruitment services is. Know which conversation you are having before you dial.

Sole-trader-heavy trades (the classic bought list: plumbers, electricians, builders) sit overwhelmingly on the TPS, not the CTPS. Teams that screen "companies only" against CTPS and call the rest are breaking the law at scale without knowing it. This single misunderstanding accounts for a remarkable share of small-business PECR breaches.

The pre-campaign checklist

  1. List screened against TPS and CTPS, certificate dated and filed
  2. Own do-not-call and suppression lists applied, including opt-outs from every channel
  3. Caller ID presents a number you control that accepts callbacks
  4. Recording notice plays by default; lawful basis documented
  5. Retention defined: recordings purged on schedule, transcripts minimised
  6. Named owner for the confirmation, recorded where auditors can find it

Ringby bakes 2, 3 and 4 into the product: workspace DNC enforced at serve time, opt-outs suppress across every campaign automatically, recording notice plays by default, and activating a campaign requires a named TPS/CTPS confirmation that lands in your audit log. Items 1, 5 and 6 remain yours, as they should: no software can consent on your behalf. See how it works.

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