Yes, but narrower than most agents assume — it covers business-relevant messages only, and it can be taken back.
Short answer
Yes. The CRTC’s own guidance confirms a business-card exemption: implied consent exists to message someone whose business card you hold, but only where “the message relates to the recipient’s role, functions or duties in an official or business capacity” — not a general newsletter — and only until they opt out.
The CRTC’s FAQ on CASL confirms the business-card exemption directly: holding someone’s card gives you implied consent to send them a commercial electronic message, provided the message “relates to the recipient’s role, functions or duties in an official or business capacity.” A note following up on a specific conversation at an open house or a networking event fits; a generic monthly market newsletter is a much harder fit for “relates to their role or duties.”
Where CASL’s inquiry-based implied consent simply expires after six months without anyone doing anything, the CRTC guidance notes the recipient can withdraw consent at any time by opting out — there is no fixed calendar expiry on the business-card exemption itself, but a single unsubscribe request ends it immediately.
The same guidance describes a separate first-contact exemption: you may send one message without consent following a referral, provided the referrer has an existing relationship with both you and the recipient, and the referral details are named in the message itself. That covers exactly one message — anything beyond it needs consent obtained the ordinary way.
Whether you rely on the business-card exemption or a referral, the sender still has to identify themselves and, if identification isn’t practical in the message body, provide “a hyperlink to a webpage containing this information” that is readily accessible at no cost.
See also: the broader six-month inquiry-based consent rule and the separate rules that apply to a phone call instead of a message
A 30-minute call is enough to sort what you can send, to whom, and for how long.
