Texting Canadian Prospects: The Four CASL Doors a B2B Seller Can Use

Why Canada is worth a text, and why CASL decides how#

StatCounter's September 2026 mobile data puts iOS at 64.89% of Canadian mobile traffic, against 53.51% in the US (read 5 Oct 2026). More of a Canadian list sits on iMessage than a US list does.

Canada's Anti-Spam Legislation, S.C. 2010, c. 23, decides how you may text that list. Every quote below comes from the Justice Laws consolidation, last modified 28 Sep 2026 and read 5 Oct 2026.

Section 1 defines an electronic address as an email, instant messaging, telephone or similar account. An iMessage thread and an SMS thread both qualify, so CASL reads a sales text exactly as it reads a sales email.

• Location: section 12(1) applies the ban whenever a computer system in Canada is used to send or access the message. A US team texting a phone in Toronto is inside the law.
• Canadian mobiles share the +1 country code with the US. The area code (416 Toronto, 604 Vancouver, 514 Montreal, among others) is the only tell in the number itself.
• Voice is treated differently. Section 6(8) excludes a live two-way voice call between individuals, so a call and a text to the same prospect follow different rules.

CASL starts from a ban, and asking for consent counts#

Section 6(1) prohibits sending a commercial electronic message to an electronic address unless the recipient consented, expressly or by implication, and the message meets the content rules in section 6(2).

A message is commercial when one of its purposes is to encourage participation in a commercial activity. An offer, a promotion, or a link to a page that sells all count (section 1(2)).

Section 1(3) closes the obvious workaround. A message that asks for consent to send commercial messages is itself a commercial electronic message, so a cold text asking may I text you is already covered.

• Burden: section 13 puts the onus of proving consent on the person who says they have it. With no record, assume you have no consent.
• Personal exposure: section 31 makes an officer, director or agent who directed or acquiesced in a violation liable for it, and section 32 makes an employer liable for its reps.
• Defense: section 33 clears a person who shows due diligence to prevent the violation. A written consent policy and per-contact records are what that diligence looks like.

Door one: a number the prospect published#

Section 10(9)(b) implies consent when the person published, or caused to be published, the address you text. Three conditions apply. Check all three before each campaign, not once.

Cold B2B outreach to Canada usually walks through this door, and it is narrower than most teams assume. The test is publication plus relevance, and a data vendor having the number satisfies neither.

• The number was conspicuously published by the person or on their behalf: a company team page, a website contact block, a published email signature.
• The publication carries no statement that the person does not want unsolicited commercial messages. A no solicitations line next to the number shuts the door.
• The message is relevant to the person's business, role, functions or duties. Texting a published procurement lead about procurement software fits. Texting them about a personal loan does not.
• Evidence to keep: the URL, a screenshot, and the date you saw it. Under section 13 that record is your consent.

Door two: a number the prospect handed you#

Section 10(9)(c) implies consent when the person disclosed the address to you directly without saying they do not want unsolicited commercial messages, and your message is relevant to their business role.

Trade shows, business cards, a mobile number typed into an email signature on a reply to your rep: each is a disclosure to the sender. The relevance test from door one applies here too.

• On the statute's wording, a number disclosed to your rep covers your company's texts too, because section 10(9) names whoever sends, causes or permits the message.
• A number disclosed to someone else does not travel with it. A list bought from an event organizer is the organizer's disclosure, not yours.
• Log who received the number, where and when. A badge scan export with a timestamp is a better record than a rep's memory.

Door three: a recent business relationship#

Section 10(10) defines an existing business relationship, and each kind carries a clock. Once the clock runs out, the implied consent ends with it, whether or not anyone unsubscribed.

A separate exclusion in the Electronic Commerce Protection Regulations, SOR/2013-221, section 3(a)(ii), lifts section 6 entirely between organizations that already have a relationship.

• Two years: a purchase or lease, an accepted business opportunity, a barter, or a written contract in force or expired within the two years before the message.
• Six months: an inquiry or application the person made to you about any of those things. A prospect who asked for pricing in April is out of this door by October.
• The B2B exclusion needs two things: the organizations have a relationship, and the message concerns the activities of the organization you are texting. A cold prospect has no relationship, so it does not apply.
• Section 10(12) carries an existing business relationship over to a buyer when the business is sold.

Door four: a named referral, once#

Section 4(1) of SOR/2013-221 lifts the consent requirement for the first commercial message sent after a referral. The conditions are specific, and the exemption covers one message only.

Referrals are where B2B teams tend to text first and check later. The rule rewards the opposite order: confirm the chain of relationships, then send one message that names the referrer.

• The referrer must have a business, non-business, family or personal relationship with you and with the person you text. Both links are required.
• The message must give the referrer's full name and say it is sent because of the referral.
• The exemption reaches consent only. The first referral text still needs the identification and unsubscribe described below.
• After that first message, you need one of the other doors, or express consent given in reply.

What every text to a Canadian must carry#

Section 6(2) and the CRTC's Electronic Commerce Protection Regulations, SOR/2012-36, set the content of every commercial message, whichever door you used to send it.

A text has little room. Section 2(2) of SOR/2012-36 lets you post the identification and the unsubscribe on a web page reached through a link set out clearly and prominently in the message.

• Identification: the name you do business under, the client's name if you text on someone's behalf, and which of you is sending (SOR/2012-36, section 2(1)).
• Contact: a mailing address plus a phone number, email address or web address. Section 6(3) requires that contact information to stay valid for at least 60 days after the text.
• Unsubscribe: section 11(1) requires a free way to opt out by the same means, so a reply has to work, plus an electronic address or web link where the request can be sent.
• Deadline: section 11(3) requires the opt-out to take effect without delay, and no later than 10 business days after it is sent.

What to change before you text a Canadian number#

CASL turns consent from a habit into a field. Each Canadian contact needs a recorded basis before the first text, and the basis decides how long you may keep texting them.

Blue Reacher catches standard opt-out words and plain-language requests, suppresses the contact on every line within seconds, and logs each event in an exportable audit trail (bluereacher.com/features/opt-out-handling).

Blue Reacher handles the stop side. The consent basis for each Canadian contact, and the read on your own offer, stays with you and your counsel.

• Flag Canadian area codes in your CRM so the list splits by country before a campaign starts.
• Add a consent basis field: published, disclosed, relationship, referral or express, plus the evidence and the date.
• Set an expiry on inquiry-based contacts six months after the inquiry, and on customer contacts two years after the last purchase or contract.
• Add a short link to a page with your business name, mailing address, contact details and an unsubscribe form, and keep it live for at least 60 days after every send.
• For referrals, put the referrer's full name and the word referral in the first text, and stop there until the prospect replies.

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