Canada’s Anti-Spam Legislation (CASL) covers texts as well as email: an electronic address includes a telephone account, and an electronic message includes a text message (CASL s. 1). Here is what it requires when you text rental prospects.
Do you need consent to reply to a renter’s text?
No. Section 6 of CASL, which holds its consent, identification and unsubscribe rules, does not apply to a commercial message sent in response to a request, inquiry or complaint, or otherwise solicited by the recipient (Electronic Commerce Protection Regulations, SOR/2013-221, s. 3(b)).
Answering a question about availability, sending the details a renter asked for and booking the showing they requested are replies. Once you go beyond what they asked, for example to promote another unit, treat the text as a commercial message.
What does a commercial text need?
Consent, sender identification and a way to unsubscribe. Section 6 prohibits sending a commercial electronic message without the recipient’s express or implied consent, and requires each one to identify the sender and anyone it is sent for, give contact information and set out an unsubscribe mechanism (CASL s. 6).
A message is commercial when it would be reasonable to conclude that one of its purposes is to encourage participation in a commercial activity (CASL s. 1). A text announcing a price drop or a new vacancy fits that description.
The CRTC’s regulations list the identification: the name you do business under, the name of anyone you send for, a statement of which is which, and a mailing address plus a phone number, email address or web address. If that cannot practicably fit in a text, it may go on a web page reached through a clear, prominent link in the message (CRTC regulations, s. 2). The contact information must stay valid for at least 60 days after you send the message (CASL s. 6).
How long can you follow up after an inquiry?
Six months on implied consent. CASL implies consent where you have an existing business relationship with the person, and an inquiry or application they made in the six months before your message, about the purchase or lease of a product, a service, land or an interest in land, creates one (CASL s. 10).
After that, you need express consent, so ask while the conversation is active, for example whether the renter wants texts about other units. A request for consent must identify who is asking and say that the person can withdraw consent (CRTC regulations, s. 4).
How fast must you act on an unsubscribe?
Within 10 business days. The mechanism must let the person unsubscribe at no cost, by the same electronic means where practicable, so by text for a text, and it must stay valid for at least 60 days after your message (CASL s. 11).
You must act on the request without delay, and no later than 10 business days after it is sent. The maximum penalty for a violation is $1 million for an individual and $10 million for any other person (CASL s. 20).
Which opt-out words should you recognize?
STOP and ARRET, at a minimum. CASL names no keywords, but Twilio’s Canadian guidelines say texting programs should support HELP and STOP, and similar messages, in the user’s local language (Twilio Canada guidelines). Twilio’s default opt-out keywords are English only unless you add other languages (Twilio).
The Canadian Telecommunications Association’s short code rules make STOP and ARRET mandatory and ask programs to also recognize FIN, ANNULER, QUITTER and DESABONNER (short code rules, January 2026). Those rules govern short codes, not local numbers, but they are a good list of what French-speaking renters may type. Accept ARRÊT with the accent too.
Does a Canadian number need carrier registration?
Not to text Canadian phones. Twilio’s Canadian guidelines list no pre-registration for domestic local numbers, while toll-free numbers need verification and short codes take 12 to 16 weeks to provision (Twilio Canada guidelines).
A renter with a US phone number is different. Twilio says US and Canadian local numbers must be registered under A2P 10DLC, the standard US carriers enforce, before they send messages from an application to US recipients (Twilio).
The rules at a glance
| Situation | What you need | Source |
|---|---|---|
| Replying to a renter’s inquiry | No consent; section 6 does not apply | SOR/2013-221, s. 3(b) |
| Commercial text within six months of an inquiry | Implied consent, plus identification and an unsubscribe | CASL ss. 6, 10 |
| Commercial text after six months | Express consent | CASL ss. 6, 10 |
| Identification | Business name, who it is sent for, mailing address and one other contact; a link if it does not fit | CRTC regulations, s. 2 |
| Unsubscribe | Free, same means, honoured within 10 business days | CASL s. 11 |
| French opt-out words | ARRET mandatory on short codes; the user’s language expected | Canadian Telecommunications Association; Twilio |
| Canadian number to a Canadian phone | No carrier pre-registration | Twilio |
| Canadian number to a US phone | US A2P 10DLC registration | Twilio |