Townsend has cast his net wide after 19 players under consideration were unavailable for selection, including experienced loose-forward John Barclay, lock Richie Gray and both first-choice hookers Fraser Brown and George Turner.
It will be a worry for Townsend to be missing so many players ahead of the World Cup later this year, with the Six Nations providing vital fine-tuning for the global event where Scotland have been pooled with Ireland and hosts Japan.
Uncapped hookers David Cherry (Edinburgh), Jake Kerr (Leicester Tigers) and Grant Stewart (Glasgow Warriors) will stake a claim for a place at the tournament.
Others included are back-row Gary Graham (Newcastle Falcons), tight-head prop D'Arcy Rae (Glasgow Warriors), and centres Sam Johnson (Glasgow Warriors) and Chris Dean (Edinburgh), who have also yet to play international rugby.
Townsend says he is not afraid to blood new players though, even this close to the World Cup.
"There's certainly been a lot of improvement from this group of players in recent seasons and I believe there's much more to come," he said in a media release from Scottish Rugby.
"They've a genuine desire to get better and reach their potential in what is a huge year for our sport.
"In the past 18 months we've played 18 test matches and have introduced 18 new players to test-level rugby.
The team will be captained by scrumhalf Greig Laidlaw.
Scotland open their Six Nations campaign at home to Italy on Feb. 2. They finished third in 2018 after victories over England, France and Italy but were tempered by away losses to Wales and champions Ireland.
Forwards: Alex Allan, Adam Ashe, Simon Berghan, Jamie Bhatti, David Cherry, Allan Dell, Grant Gilchrist, Gary Graham, Jonny Gray, John Hardie, Jake Kerr, Stuart McInally, Willem Nel, D’Arcy Rae, Jamie Ritchie, Sam Skinner, Grant Stewart, Josh Strauss, Tim Swinson, Ben Toolis, Hamish Watson, Ryan Wilson
Backs: Chris Dean, Darcy Graham, Nick Grigg, Sam Johnson, Chris Harris, Adam Hastings, Stuart Hogg, George Horne, Pete Horne, Huw Jones, Lee Jones, Blair Kinghorn, Greig Laidlaw (captain), Sean Maitland, Ali Price, Finn Russell, Tommy Seymour. (Reporting By Nick Said Editing by Christian Radnedge)