Pay-Per-Call Publisher Compliance Checklist: How to Keep Your Calls Payable

Why does compliance matter more for publishers than it seems?

A network's buyers are contractors, law firms, insurance agencies, medical practices, and financial companies, and many are regulated. When a publisher sends a non-compliant call, the buyer disputes it, the network reverses it, and if it happens more than a few times the publisher is removed. Compliance is the difference between a payout and a reversal.

This checklist is general information for publishers on Axel PR Exclusive Calls and is not legal advice. Rules vary by state and by vertical, and you should consult your own counsel about your specific traffic and creative.

What does consumer-initiated actually require?

The foundation of every rule is that a real person chose to dial. Everything the network pays for flows from that. The following are never consumer-initiated and are never payable.

• Robocalls or prerecorded messages that prompt a consumer to call or press a key
• Autodialed outbound calls that are transferred to a buyer as if they were inbound
• Incentivized traffic: rewards, sweepstakes, or payment to a consumer for calling
• Spoofed or masked caller ID that hides the consumer's real number
• Misleading creative that gets a consumer to call for something other than what the buyer offers

If you run a call center that warm-transfers, the consumer must have contacted you first about that service, and you must be able to show it. An inbound line the consumer dialed is fine. An outbound campaign that then transfers is not.

Which traffic sources are approved?

Approved sources share one property: the consumer sees an honest description of a service and decides to call. On Axel PR the approved list is search, maps, display, social, owned sites, and directories. Each has its own things to watch.

• Search: call extensions and call-only ads on service keywords. Do not bid on a buyer's brand name without written network approval
• Maps and local listings: the listing must represent a real business or a clearly labeled referral service, not a fictional storefront
• Display: say what the service is and who answers, in plain terms. No interstitial or forced-click placements
• Social: paid social must comply with the platform's policies for the vertical, and organic posts must not imply endorsement by the buyer
• Owned sites: service pages and articles with a tracked number. Disclose that calls may be routed to a partner provider
• Directories: category pages that route callers by service and area. The directory must not list a buyer by name unless it has permission

Purchased call lists and any source you cannot name and document are not approved. If you use sub-publishers, their traffic is your responsibility.

What does honest creative look like?

The consumer must understand what they are calling for and roughly who will answer. Use this test on every ad, page, and listing.

• Describe the service, the area, and how to reach it. Nothing else is required
• Never impersonate a specific buyer: no buyer's name, logo, or slogan unless that buyer approved the creative through the network
• Never imply government affiliation. Words like 'official', 'federal', 'Medicare' as a brand, or agency seals will get creative rejected and a publisher removed
• Do not promise outcomes: no 'guaranteed approval', 'we win every case', 'eliminate your debt'. Only claims the buyer makes and can support
• Do not use urgency you cannot back: 'call in the next 10 minutes' countdowns and fake scarcity are misleading creative
• Disclose that the number connects to a partner or a network of providers where the consumer might reasonably assume otherwise

What are the rules on caller ID, recording, and disclosures?

Caller ID passthrough is required. The buyer must receive the consumer's real number, both so they can call back and so duplicates can be detected. Any routing stack that rewrites the caller ID to a generic or publisher-owned number breaks qualification and will be treated as spoofing.

Calls on the network are recorded for quality and dispute resolution, and some states require that all parties be notified. The network handles notification on its side of the call. If you run an IVR or a call center step before the transfer, you are responsible for any disclosure required at your step. When in doubt, disclose.

Some buyers, most often in Medicare and debt relief, require a specific disclosure before transfer. Follow it exactly and keep a copy of the language you used.

How do TCPA and Do Not Call rules apply to a publisher?

A pure inbound publisher has limited TCPA exposure, because the consumer initiated the contact. Exposure begins the moment you place an outbound call or text.

• Any outbound follow-up, including a callback to a consumer who hung up, a missed-call text, or a reminder, needs a lawful basis. Prior express written consent is the standard for marketing calls and texts to mobile numbers using an autodialer or prerecorded voice
• Consent must be clear, specific to the seller and the purpose, and documented with the date, time, source, and exact language shown
• Scrub against the National Do Not Call Registry and applicable state lists before any outbound marketing call, unless you have a documented exemption
• Honor time-of-day rules for outbound calls and keep an internal do-not-call list for anyone who asks not to be contacted
• Do not send texts to numbers you collected for calls unless the consumer consented to texts specifically

The simplest model is also the safest: generate the inbound call, route it live, and do not follow up by phone or text. If you do follow up, treat it as regulated marketing with its own consent and records.

How should you handle opt-outs and complaints?

A consumer who says stop, asks not to be called, or complains must be honored immediately and logged. Add the number to your suppression list, tell the network if the complaint concerns a routed call, and keep the record. A handled, documented complaint is a normal cost of business. An ignored one gets a publisher removed.

What gets a publisher removed?

The categories are consistent across networks.

• Any robocall, autodialer, incentivized, or spoofed traffic, usually on the first confirmed instance
• Impersonating a buyer, a brand, or a government agency in creative
• Sustained high dispute rates for wrong service, out of area, or no intent after being asked to fix targeting
• Undisclosed sub-publishers or sources that cannot be documented on request
• Failing to honor opt-outs or ignoring consumer complaints
• Misrepresenting identity or ownership during onboarding, or a false W-9 or W-8

What documentation should you keep?

The publishers who resolve disputes fastest can show their work. Keep the following, organized by campaign, for as long as your agreement and applicable law require.

• Source records: which tracked number ran where, on what placement, with what targeting, and when
• Creative files and approvals: every ad, landing page, and listing as it ran, with the date and any network approval
• Disclosure language: the exact text of any partner, recording, or vertical-specific disclosure, and where it appeared
• Consent records for any outbound follow-up: date, time, source, and the language the consumer saw
• Suppression and opt-out logs with the date each request was honored
• Sub-publisher agreements and their source documentation, if you use them
• Your call-level statements and dispute correspondence from the network

The one-page version

• Only consumer-initiated calls. No robocalls, autodialers, incentives, spoofing, or misleading creative
• Only approved sources: search, maps, display, social, owned sites, directories. Document every one
• Creative describes the service honestly. No buyer impersonation, no government implication, no outcome promises
• Pass real caller ID through. Disclose recording where required at your step
• Treat any outbound follow-up as regulated: consent, DNC scrub, time-of-day, records
• Honor opt-outs immediately and log them
• Keep source, creative, consent, and statement records organized by campaign

This is general information, not legal advice. Review the compliance page for current requirements before you launch.