How long does implied consent last under CASL?

Implied consent duration depends on the relationship type. For existing business relationships-where someone purchased a product, entered a contract, or became a member-implied consent lasts 24 months from the last transaction. If a customer bought from you 18 months ago, you have 6 months of implied consent remaining.

For inquiries-where someone requested information, a quote, or applied for something but didn't complete a transaction-implied consent lasts only 6 months from the inquiry. This shorter window reflects the weaker relationship: they showed interest but didn't commit.

When implied consent expires, you must immediately stop sending commercial email unless you've obtained express consent during the implied consent window. Best practice: implement consent conversion campaigns well before expiration, asking contacts to confirm they want to continue receiving communications. Don't wait until month 23 to request explicit opt-in-build conversion requests into your regular communication strategy. Implied consent is borrowed time; use it to build genuine subscriber relationships, not to delay the inevitable compliance requirement.