Does CAN-SPAM apply to a one-to-one B2B introduction email?

Short answer: does CAN-SPAM reach B2B email?

It can. The CAN-SPAM Act regulates commercial electronic mail, and it is generally understood to cover business recipients as well as consumers. Whether a particular introduction counts as "commercial" depends on its primary purpose, which is a fact question about the message, not a label you choose.

Read the FTC's CAN-SPAM compliance guide and the statute itself before relying on this page; treat the summary below as a list of questions to check, not a ruling. This is general information, not legal, tax or financial advice. Confirm with your own counsel before acting.

Why does a permissioned one-to-one introduction lower the risk?

The program is built around single, owner-approved introductions, not bulk sends. A partner introduces a company that has agreed to be contacted, usually in an email the owner has seen or requested. That pattern differs from the cold, list-driven messages the law was written to curb in three ways.

1. Consent exists before the message. The owner agreed to the introduction.
2. Volume is one. One message to one person is not a campaign.
3. The purpose is mutual. The owner asked to hear about the program.

None of this makes a message exempt. A one-to-one email that promotes a commercial product or service can still be a commercial message, so the basics below apply as good practice either way.

The basics a commercial email should meet

These are the commonly cited requirements for commercial email. Confirm each against the FTC guide and the statute, because they are summarized here from general knowledge.

What does this mean in common partner situations?

Programs like this one are not for lead-list sellers or cold-outreach affiliates. See how SourceX referrals work for the permission-first model.

Disclose that you may be paid

Separate from CAN-SPAM, the FTC's Endorsement Guides address connections between a person who recommends something and the business that benefits. The agency's 16 CFR Part 255 and its FAQ on endorsements explain that a connection a reader would not expect should be disclosed. A referral reward is such a connection, so say so in the email in one plain sentence. Do not type the reward amount. Rewards are 25% of the eligible platform fees SourceX actually collects, capped at $100,000 cumulative per referred company, and they become payable only after the buyer pays and SourceX receives its fee. No reward is guaranteed.

A safe structure for the email

The company introduction email template and the introduction email builder give wording. Use this order.

1. A subject line that says what the email is.
2. One sentence on who you are to the owner and that they agreed to the introduction.
3. One sentence on what SourceX does: licensing company records to AI developers, with the company keeping ownership.
4. One sentence disclosing that you may receive a reward if a deal completes.
5. A clear way to stop receiving messages.
6. Your name and postal address.

For who replies first and when to move to BCC, see the introduction etiquette guide.

Other rules can apply

CAN-SPAM is a US federal law. If you or the recipient are elsewhere, other rules can apply, and licensed professionals have their own conduct rules on fees and communications. If your introduction crosses a border, see introducer agreements. If you also refer to other programs, see referring the same company to more than one program. Ask your counsel about referral fee clawbacks in the same conversation.

Questions for your counsel

• Is my introduction email a commercial message under the statute?
• What should my signature, subject line and opt-out wording say?
• Do my other rules, such as my profession's, require extra disclosure?
• If I use a tool, who is the sender in law?

Next step

Draft one owner-approved email, keep it plain, and register as a partner. The program applies to US companies with 50+ full-time employees at peak (contractors excluded); the employee count guide helps you check before you write.