In Canada, relationship implied consent expires and unsubscribes take ten business days
How long does CASL implied consent last, and how fast must I honour Canadian unsubscribes?
In one sentence
Canadian implied expires (about two years after a purchase, shorter for inquiries) — unsubscribes must complete within ten business days.
Plain English
Under , implied is time-limited: roughly two years after certain purchases or six months after inquiries (check the exact statutory basis for your case). Express consent lasts until withdrawn. Honour unsubscribes within ten business days at most. “They bought once in 2019” is not forever.
Why it matters. Expired implied is a silent landmine for legacy lists and migration projects.
Dotted words open definitions. Full glossary.
What to do
Your move — not a lecture
Part platform, part you
The platform covers the mechanical bit. The judgement is still yours.
can suppress quickly; configure -aware footers and 10-business-day SLAs.
Your part: Dating the relationship event that started the clock, and not confusing routes.
What to do first
In your , segment Canadians whose last qualifying purchase is older than two years and who lack express . That segment is the implied-consent time bomb.
You can skip this if: You only mail Canadians with current express .
Who this applies to
Anyone relying on implied or mailing Canadians with standard footers.
Checklist
- 01Store the event date that supports implied , not only "signed up."
- 02Re- before clocks expire if the relationship still has value.
- 03Honour unsubscribes within ten business days; operationally aim for same day.
- 04Keep identification and working for 60 days after each send.
That’s enough to act. Sources and exact wording are below for counsel, bosses, or AI tools that need a citation. Not legal advice.
Proof
Exact position, enforcement, sources
For records and people who will check you. Skip if Monday’s move is already clear.
The exact position
Under 's existing-business-relationship route, qualifying purchases and similar events generally support implied for two years; qualifying inquiries generally support six months. Express consent does not expire merely because those clocks run out—it lasts until withdrawal unless limited. CEMs must identify the sender, keep contact and details valid for at least 60 days after the message, and complete unsubscribe requests without delay and no later than ten business days.
What happens if you do not
CRTC actions have included failures around proof and practices. Read current notices rather than recycling old blog summaries.
Sources
- CASL sections on implied consent periods and unsubscribe (official consolidation)Published 1 Jul 2014Read primary source
- CRTC CASL guidanceNo publisher dateRead primary source
History of this page
- Added clocks and unsubscribe SLA.