# Cold outreach regulations in Japan and domestic company practices: GPT-6.1 Sol · High (OpenAI)

AI-generated answer, not verified by Dorado, shown as produced. Asked 5 October 2026 with web search on.
Source: the AI Report Library, https://aireportlibrary.com/en/prompt/japan-cold-outreach/regulations/compare/
Comparison: https://dorado-group.jp/library/comparisons/japan-cold-outreach-regulations/
The cited links have not been checked.

## The question, as asked

What's the cold outreach regulations in Japan? and how do domestic companies deal with it?

---

## GPT-6.1 Sol · High (OpenAI)

AI-generated, unverified. Asked 2026-10-05.

**Japan permits cold business-to-business (B2B) outreach, but email has specific restrictions.** The default is prior consent, with exceptions including publicly disclosed business email addresses, business cards, and qualifying existing business relationships. Being a business recipient does **not** itself exempt an email from the law. [caa.go.jp](https://www.caa.go.jp/policies/policy/consumer_transaction/specifed_email/pdf/090901email_1.pdf?utm_source=chatgpt.com)

The key distinction is **how you obtained the contact details and which channel you use.**

For email, the main law is the **Act on Regulation of Transmission of Specified Electronic Mail**, commonly called 特定電子メール法.

| Situation | Can you send an unsolicited sales email? |
|---|---|
| A company publishes its contact email on its website, without an accompanying refusal of advertising emails | **Generally yes**, under the public-address exception. |
| The published address has “営業メールお断り” or equivalent wording alongside it | **You cannot rely on the public-address exception.** |
| Someone directly gives you their business card containing their email | **Generally yes**, under the written-address-notification exception, subject to subsequent refusals. |
| You have a qualifying existing business relationship | **Generally yes.** |
| You guess an employee’s address or obtain an unpublished address from a prospecting database | **Not automatically permitted.** You need consent or another applicable exception; possession of the address is insufficient. |

These exceptions come from Article 3 and the government’s guidance. A publicly listed company address does not authorize sending to every employee at that domain. [caa.go.jp](https://www.caa.go.jp/policies/policy/consumer_transaction/specifed_email/pdf/090901email_1.pdf?utm_source=chatgpt.com)

**Even when an exception permits the email, you still need:**

- The responsible sender’s name or company name.
- A clearly explained way to refuse future emails, using an email address or unsubscribe URL.
- Sender address and a contact channel for complaints or inquiries.
- Accurate sender information, and cessation of promotional emails after a refusal. [迷惑メール相談センター](https://www.dekyo.or.jp/soudan/contents/taisaku/1-2.html?utm_source=chatgpt.com)

A personalized, manually sent pitch does not gain an exemption simply because it is one-to-one. Also, **“May I send you information about our service?” is not a universal workaround**: government guidance treats emails seeking advertising-email consent as covered messages themselves. [caa.go.jp](https://www.caa.go.jp/policies/policy/consumer_transaction/specifed_email/pdf/090901email_1.pdf?utm_source=chatgpt.com)

Other channels work differently:

| Channel | Regulatory position |
|---|---|
| **Cold telephone calls** | Genuine business-purpose transactions are generally excluded from the consumer telephone-sales provisions of the Specified Commercial Transactions Act. Consumer calls have identification requirements and a prohibition on continuing or repeating solicitation after refusal. [no-trouble.caa.go.jp](https://www.no-trouble.caa.go.jp/what/telemarketing/?utm_source=chatgpt.com) |
| **Website contact forms** | Japanese providers actively offer *フォーム営業*. However, a publicly accessible form is not blanket permission: its purpose, terms, and “no sales” wording matter. Providers themselves instruct users to exclude prohibited targets. [株式会社エンカレッジ](https://www.encourage-sol.jp/column/form_sales/20260724_column?utm_source=chatgpt.com) |
| **LinkedIn and other ordinary in-app messages** | These are generally outside the email/SMS regime, but platform restrictions apply. LinkedIn prohibits unauthorized automated messaging and scraping. [salt.iajapan.org](https://salt.iajapan.org/wpmu/anti_spam/admin/2008_qanda/qa_basic/?utm_source=chatgpt.com) |
| **Short Message Service (SMS)** | Advertising SMS is covered by the email law. It is not an alternative route around consent requirements. [caa.go.jp](https://www.caa.go.jp/policies/policy/consumer_transaction/specifed_email/pdf/specifed_email_180709_0001.pdf?utm_source=chatgpt.com) |

There is also a separate privacy layer. Under the **Act on the Protection of Personal Information (APPI)**, identifiable employee information remains personal information even when publicly available. Public availability does not remove obligations concerning use purposes and handling. The Personal Information Protection Commission explicitly recognizes ordinary business-card follow-up for the collecting company’s advertising, while requiring compliance with the email law too. [ppc.go.jp](https://www.ppc.go.jp/personalinfo/legal/guidelines_tsusoku/?utm_source=chatgpt.com)

**How Japanese companies handle it in practice**

These are documented examples, rather than evidence that every domestic company follows the same approach:

| Approach | Concrete Japanese example |
|---|---|
| **Email publicly listed business addresses, with opt-out controls** | **B.O.N’s Reachill**, launched September 2026, says it restricts recipients to legally eligible addresses, includes sender and opt-out information, and stops after refusal. [株式会社B.O.Nのプレスリリース](https://prtimes.jp/main/html/rd/p/000000002.000188229.html?utm_source=chatgpt.com) |
| **Build email lists from business cards and existing contacts** | **Rakus’s 配配メール** support documentation says many customers use business cards, customer lists, and internal databases, while explaining the consent exceptions. [配配メールサポートサイト](https://support.haihaimail.jp/utilization-lecture/destination/?utm_source=chatgpt.com) |
| **Use contact-form outreach with exclusions** | **Encourage** instructs users to remove companies prohibiting sales approaches, previous stop requests, and duplicate targets. [株式会社エンカレッジ](https://www.encourage-sol.jp/column/form_sales/20260724_column?utm_source=chatgpt.com) |
| **Explicitly refuse unsolicited email as a recipient** | **Dai-Ichi Tsushinsha**, a Kodansha Group company, publishes its contact email alongside a request not to send sales or other specified advertising emails. [講談社グループ](https://www.ittsu.ne.jp/contact/?utm_source=chatgpt.com) |

**For your outreach, my practical recommendation:** record the source and permission basis for each email address, check refusal wording before sending, include a clear opt-out, and maintain a shared suppression list. Public company inboxes provide a clearer basis for cold email than guessed employee addresses. They may, however, require another step to reach the decision-maker. That last trade-off is a practical assessment, not a statutory rule.