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How Long does Implied Consent Last for past Customers in Canada?

Under Canada’s Anti-Spam Legislation (CASL), implied consent for past customers is temporary and depends on the nature of the relationship.

For an existing business relationship stemming from a purchase, implied consent lasts for two years from the date of the last transaction.

If the relationship is based on a written inquiry rather than a purchase, the window is much shorter, lasting only six months from the date of the inquiry.

To maintain a compliant email list, businesses should consider the following:

  • Conversion Strategy: It is recommended to use the two-year or six-month window as an opportunity to send a re-consent request to convert the recipient to express consent, which does not expire unless revoked.
  • Expiration: Once these specific timelines pass, the implied consent expires, and you can no longer legally send commercial electronic messages (CEMs) to those individuals unless you have obtained express permission.
  • Record Keeping: You must maintain verifiable records of the transaction or inquiry to prove the timeline of the implied consent for at least three years.

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