This guide is educational information, not legal advice. Canada’s Anti-Spam Legislation (CASL), privacy obligations, provider terms, carrier rules and destination-country requirements can overlap. The facts and message context determine which requirements apply.
Does CASL apply to business text messages?
Commercial SMS messages sent to an electronic address can be subject to CASL. A message may be commercial when one of its purposes is encouraging participation in a commercial activity—even when it also provides useful information. The CRTC’s CASL FAQ (opens in a new tab) specifically discusses text messages and explains that the law applies across technologies.
Classification is contextual. A requested support reply, a message completing a transaction, an appointment notice and a promotion are not interchangeable. Some messages or relationships can fall within exclusions, exemptions or special conditions, but a business should document why it relies on one. A customer enquiry is not a blanket invitation to send unrelated promotions indefinitely.
What is the difference between express and implied consent?
Express consent is a proactive agreement to receive defined commercial messages. A sound opt-in explains who will send, the purpose or scope, how to withdraw and other required information. Avoid pre-checked boxes, buried language or bundling optional marketing consent with an unrelated service requirement.
Implied consent can arise only under specific statutory facts and is often limited by conditions and time. An existing business relationship may support implied consent in some circumstances, but it is not permanent permission for every campaign. The CRTC’s implied-consent guidance (opens in a new tab) describes qualifying relationships and relevant periods. Confirm the current rule and its application to the actual relationship.
The sender bears the burden of proving consent. Buying a list, scraping published numbers, receiving a business card, seeing a number online, having contacted someone before or having a customer account does not automatically authorize marketing texts. Consent must also match the sender, recipient, purpose and scope, and it can be withdrawn.
What should a consent record contain?
A useful record should allow the business to reconstruct what the recipient agreed to—not merely show a database field marked “yes.” Keep data appropriate to the purpose and respect applicable privacy obligations.
- The recipient’s phone number and the date and time consent was captured.
- The method and source, such as a named web form, signed document or recorded workflow.
- The disclosure language and version shown at that time.
- The campaign, purpose, sender and message scope covered.
- Relevant form, page, IP or source evidence where appropriate and lawfully collected.
- Confirmation evidence, changes in scope and any withdrawal or suppression date.
Store records securely, limit access and define retention. If consent moves between a website, CRM and messaging provider, preserve the original evidence and a traceable synchronization history. The ISED consent overview (opens in a new tab) is a useful starting point.
What sender identity and contact information belong in a message?
A commercial electronic message generally needs to identify the sender and, where applicable, the person on whose behalf it is sent, provide required contact information and include a working unsubscribe mechanism, subject to the legislation’s details and exceptions. Sender names, message content, URLs and destination pages should be truthful and consistent.
SMS space is limited. Where the law permits required information to be accessed through a link, make that link clear, accessible and controlled by the actual sender. Do not disguise a redirect, imitate another brand or use a misleading domain. The Competition Bureau explains that false or misleading representations can occur in electronic messages and web addresses (opens in a new tab). This guide does not prescribe exact text for every campaign.
How should STOP requests and suppression work?
Make unsubscribe clear, readily performed and without cost beyond any ordinary charge associated with the recipient’s service. “Reply STOP to unsubscribe” is a familiar instruction when two-way replies and the provider workflow support it; other compliant mechanisms may be needed for a particular sender type or destination.
The CRTC guidance says an unsubscribe request must be honoured within 10 business days. Operationally, suppress the recipient as quickly as possible. Acknowledge only when appropriate, and do not turn confirmation into another promotion. Synchronize the opt-out across the relevant campaigns, CRM lists, automations and vendors so a later import does not reactivate the number.
Test HELP and STOP handling before launch, monitor failures and retain an audit trail. Never rotate numbers, alter spelling or disguise identity to bypass an opt-out or carrier block.
Why are consent, registration and number capability separate?
Permission to send
CASL consent, an applicable exception or another documented legal basis addresses the relationship with the recipient.
Identity in message
Truthful sender details, contact information and unsubscribe handling address message transparency.
Carrier eligibility
Provider or carrier verification addresses the business, use case, sender and network requirements.
Number capability
The exact number, destination, direction and SMS/MMS configuration determine technical availability.
| Layer | What it addresses | What it does not establish |
|---|---|---|
| CASL consent or exception | Legal basis and recipient relationship. | Carrier approval, number capability or delivery. |
| Telecom or BITS registration | A provider’s applicable telecommunications regulatory status. | Recipient consent, sender verification or permission for a campaign. |
| Provider/carrier verification | Business identity, sender and proposed messaging use case. | A legal opinion, consent or guaranteed delivery. |
| Number capability | Whether the specific number and route support the requested messaging. | Permission, content acceptability or universal reach. |
Office Spaces Inc identifies its BITS licence file as 8190-O151-202601012. Read the OfficeSpaces BITS licence guide: the licence does not create CASL consent, messaging authorization, carrier approval or a delivery guarantee.
Which number types can support business messaging?
Local long-code numbers may support conversational or application-to-person messaging when enabled and eligible. Toll-free numbers can require a separate verification process. Short codes generally follow dedicated application and program rules. Alphanumeric senders are supported only in certain countries and may not accept replies. A landline, voice-only number or otherwise ineligible number may not support SMS or MMS at all.
Two-way replies, STOP handling, media, country coverage and throughput can differ by provider, carrier, destination and use case. Porting voice service does not prove messaging capability; review the Canadian number-porting guide before a move. Never assume every OfficeSpaces number, country or plan supports SMS or MMS.
What may providers and carriers review?
- Legal business identity, website, address and responsible contact.
- The intended use case, recipient geography and restricted industry considerations.
- Sample messages and whether the sender and linked domain match the business.
- The consent flow, opt-in wording and evidence captured.
- STOP, HELP, support and complaint-handling processes.
- Privacy and terms links, expected volume and disclosed frequency.
Some networks refer to brand/campaign review, toll-free verification, short-code approval or sender registration. There is no single universal Canadian “A2P registration” that authorizes all SMS. A completed review is not legal advice and does not guarantee delivery; filtering, routing, recipient settings and network conditions still matter.
How should businesses manage frequency and quiet operations?
Tell recipients what they can reasonably expect. Cap sends by recipient and campaign, prevent duplicates, avoid sudden bursts and account for each recipient’s time zone. Use quiet hours, staged rollouts and human review for sensitive content. If someone replies, opts out or resolves the issue, stop or reassess automations where appropriate.
Monitor complaints, opt-outs, failed deliveries and frequency escalation. Do not invent a universal carrier limit: thresholds vary by sender, route, provider, carrier and current policy. The safest operating rule is to send only useful, expected messages at a frequency consistent with the disclosed purpose.
What content may be restricted or prohibited?
Illegal or deceptive offers, phishing, identity spoofing, harassment, hateful or exploitative content, malware and attempts to evade filtering are broadly unsafe and commonly prohibited. Additional requirements or restrictions can apply to regulated, age-restricted or high-risk products and services. Shortened or mismatched URLs can also raise trust and filtering concerns.
Review the provider’s current acceptable-use rules, carrier requirements and laws for every destination. Do not continue after an opt-out, rotate numbers to evade blocks or disguise the source. The CRTC publishes an overview of CASL legislation, regulations and guidance (opens in a new tab).
Are transactional, conversational and promotional messages treated the same?
| Message type | Example | What to check |
|---|---|---|
| Requested conversation | Answering a customer’s specific question or quote request. | Keep the response within the request; do not treat it as open-ended promotion permission. |
| Transactional or service | Appointment, account or purchase information. | Confirm purpose, content and any applicable CASL provision; avoid adding unrelated promotion. |
| Promotional | A discount, renewal offer or new-product campaign. | Document consent or the precise basis relied upon, identity, unsubscribe and eligibility. |
Names are not legal conclusions. A “transactional” label cannot cure promotional content, and an exception can depend on exact facts. The CRTC’s CASL information-session material (opens in a new tab) provides context about exclusions and exemptions.
What should be checked before sending?
- Classify
- Prove consent or basis
- Identify
- Verify sender and number
- Review content
- Send cautiously
- Honour opt-outs
- Classify the purpose. Separate support, transaction and promotion; identify every commercial element.
- Document the basis. Preserve consent evidence or the facts supporting a claimed exception.
- Confirm identity and unsubscribe. Test sender details, links, STOP and suppression synchronization.
- Verify technical eligibility. Confirm sender registration, number type, destination, SMS/MMS and intended use.
- Review content and timing. Check truthfulness, restrictions, frequency, quiet hours and privacy.
- Test and monitor. Use controlled internal tests, observe errors and act on complaints and opt-outs.
What should OfficeSpaces customers confirm?
Before relying on the OfficeSpaces virtual phone system, confirm that the account has an owned or assigned messaging-capable number; the destination country and carrier are supported; SMS or MMS is enabled; required registration is accepted; and the intended use, content and recipient basis are appropriate.
Also confirm rates, limits, sender identity, opt-out processing, monitoring and support. The phone-system demo is illustrative and does not establish account capability. Review the support guide, terms of use and privacy policy, then contact OfficeSpaces for account-specific checks.
Frequently asked questions
Does an existing customer relationship permit marketing texts?
Not automatically. It may support time- and condition-limited implied consent in defined circumstances, but the sender must prove the facts, scope and applicable period.
Can I text a number from a business card or public website?
Public availability is not automatic marketing permission. The circumstances, conspicuous publication conditions, relevance and other legal requirements matter.
How quickly must a STOP request be processed?
The CRTC guidance says within 10 business days. Suppress it as quickly as operationally possible and synchronize the change across relevant systems.
Can I reply to a customer enquiry?
A focused reply may be treated differently from a promotional campaign, but the enquiry is not blanket permission for future marketing. Check the content and context.
Does sender registration make a campaign lawful?
No. Provider or carrier review does not establish consent, satisfy every CASL requirement or provide a legal opinion.
Does a BITS licence authorize business SMS?
No. Telecom registration does not create recipient consent, sender approval, carrier eligibility, number capability or campaign permission.
Can every business phone number send SMS?
No. Local, toll-free, short-code, alphanumeric, landline and voice-only senders have different capabilities and requirements.
Can I message international recipients, and is delivery guaranteed?
Destination laws, sender rules, number support and carrier policies vary. Confirm each route. No provider can guarantee delivery of every message.
Sources and review notes
- CRTC: Implied consent guidance (opens in a new tab)
- CRTC: CASL FAQ, including SMS and unsubscribe guidance (opens in a new tab)
- CRTC: CASL acts, regulations and guidelines (opens in a new tab)
- CRTC: CASL information session and exemptions context (opens in a new tab)
- Competition Bureau: Representations in electronic messages and web addresses (opens in a new tab)
- ISED: Getting consent to send commercial electronic messages (opens in a new tab)
Reviewed: August 30, 2026 by the Office Spaces Editorial Team. Laws, guidance, platform rules and carrier practices change. Obtain qualified advice for uncertain or high-risk campaigns. To request a correction, email info@officespaces.co.