How long does implied consent last under CASL?

You sold something to a Canadian customer 18 months ago. Under CASL, how much longer can you email them without asking permission? 6 more months. After that, your implied consent window closes.

Here's how the clock works. If someone made a purchase, signed a contract, or became a paying member, you get 24 months of implied consent from their last transaction. If someone only requested a quote or filled out an inquiry form but never bought anything, you get just 6 months. So a purchase window is much longer. An inquiry window is short.

When the clock runs out, you must stop emailing that contact unless you've converted them to express consent (explicit opt-in) in the meantime. And this is the important part: the clock doesn't pause. If you haven't gotten their documented agreement to keep receiving email by month 24 (or month 6), you can't send anything else. Not even a "please stay subscribed" message. Silence means stop.

Best practice is to start your conversion campaigns 3-4 months before expiration, when you still have time to engage them. Ask something straightforward like "Want to keep getting our emails?" Make it obvious they're choosing to stay. Log their response. That documented yes becomes express consent, which doesn't expire. For contacts who don't respond or say no, remove them from your list. It's less fun than a big list, but it's the legally compliant way to run Canadian email. Ready to tag your contacts with their consent type and expiration date so you don't miss these windows?