A cold email footer feels like a formality, but it is the part of the message most often required by law, in more than one law at once. Marketing rules require you to identify yourself and offer an opt-out. Company law in several countries requires specific registration details on every business letter, and email counts as a business letter. US law requires a postal address.
The good news is that one well-built footer satisfies all of them. This article lists what each rule asks for, with links to the source, and ends with a template. It is general information, not legal advice.
The EU baseline: identify yourself and offer a way out
Two EU directives set the floor for every member state.
The ePrivacy Directive (2002/58/EC, Article 13(4)) prohibits sending direct-marketing email that disguises or conceals the identity of the sender on whose behalf it is sent, or that has no valid address to which the recipient can send a request to stop. This applies whether or not the country requires consent, and whether the recipient is a person or a company.
The e-Commerce Directive (2000/31/EC) adds two things for information-society services, which include commercial email:
- Article 5 requires the provider to make basic information easily, directly and permanently accessible: its name, geographic address, contact details including an email address, the trade register and registration number where it is registered, and its VAT number where it has one.
- Article 6 requires commercial communications to be clearly identifiable as such, and the person on whose behalf they are made to be clearly identifiable.
In practice that means a cold email must say who is really behind it. Sending from a personal-looking name at a look-alike domain with no company details anywhere is exactly what Article 13(4) and Article 6 are aimed at.
Germany: business-letter details and the Impressum
Germany is the clearest example of company law reaching into email. Section 37a of the Commercial Code (HGB § 37a) requires every business letter "of whatever form" addressed to a specific recipient to state the company name, its legal form, the place of business, the register court and the register number. For a GmbH, § 35a of the Limited Companies Act (GmbHG § 35a) adds all managing directors by surname and at least one full first name, and the chair of the supervisory board if there is one. German courts and chambers of commerce treat email as a business letter for these purposes.
The German competition act (UWG § 7(2) no. 3) also makes it an unreasonable nuisance to send advertising that conceals the sender's identity, that breaches the provider-information duty in § 6(1) of the Digital Services Act (DDG), or that lacks a valid address for opting out.
If you write to German recipients at all (remember that cold email to German businesses generally needs prior consent, see the rules by country), your footer needs the full set.
Sweden: name, registered office and organisation number
Swedish limited companies must show their company name, the municipality of the registered office and their organisation number on letters, order forms and invoices under the Companies Act (aktiebolagslagen 2005:551), and email to a specific business recipient is generally treated the same way. The Marketing Practices Act (20 §) requires every marketing email, to companies too, to contain a valid address where the recipient can ask for the marketing to stop.
United Kingdom: trading disclosures plus PECR
UK companies must show their registered name, registered number, the part of the UK where they are registered and their registered office address on business letters, order forms and websites under the Company, LLP and Business (Names and Trading Disclosures) Regulations 2015, regulation 25. The regulations apply to documents "in hard copy, electronic or any other form", and email is widely treated as covered.
PECR adds the marketing layer: do not disguise or conceal your identity, and give a valid address for opting out (ICO guidance).
United States: CAN-SPAM
If any recipients are in the US, the CAN-SPAM Act applies to commercial email regardless of whether the recipient is a consumer or a business. The FTC's compliance guide lists, among other things:
- header information (From, To, Reply-To, routing) must be accurate and identify the sender;
- the message must include a valid physical postal address (a street address, a registered post office box or a private mailbox);
- it must explain clearly how to opt out, the opt-out must work for at least 30 days after sending, and requests must be honoured within 10 business days;
- you remain responsible even if you hire another company to send for you.
Mailbox providers: one-click unsubscribe
Not law, but just as binding in practice: Gmail and Yahoo require bulk senders to support one-click unsubscribe through the List-Unsubscribe and List-Unsubscribe-Post headers defined in RFC 8058, and to honour unsubscribes within two days (Google sender guidelines). Cold email volumes are usually below the bulk threshold, but the headers cost nothing to add and give recipients an alternative to the spam button.
Putting it together: what to include
| Element | Why |
|---|---|
| Sender's full name and role | ePrivacy Art. 13(4), e-Commerce Art. 6, PECR: identity must not be concealed |
| Legal company name (with legal form) | e-Commerce Art. 5, HGB § 37a, UK reg. 25, Swedish ABL |
| Registration number and register | e-Commerce Art. 5, HGB § 37a, UK reg. 25, Swedish ABL |
| Registered office / postal address | e-Commerce Art. 5, UK reg. 25, CAN-SPAM postal address |
| VAT number (where you have one) | e-Commerce Art. 5 |
| Managing directors (German GmbH) | GmbHG § 35a |
| A working opt-out | ePrivacy Art. 13(4), Swedish MFL 20 §, PECR, CAN-SPAM |
| Where you found the recipient's details | GDPR Art. 14, when the address identifies a person |
A footer template
Keep it short and plain. A footer does not need to be pretty; it needs to be complete and readable.
Anna Svensson, Head of Sales
Acme Profil AB (org. no. 556677-8899, registered office Stockholm) · Storgatan 1, 111 22 Stockholm, Sweden · VAT SE556677889901
We found your company in the Swedish companies register. Not interested? Reply "stop" or unsubscribe here: [link]
That is three lines. A German GmbH would add the register court and its managing directors; a UK company would state "Registered in England and Wales, company no. ..." and its registered office.
Common mistakes
- Trading name only. "Acme" is a brand. The law asks for the registered legal name, "Acme Profil AB".
- A footer that only appears on the first email. Every message in a sequence needs it, including follow-ups.
- An opt-out that does not work. A dead link or a mailbox nobody reads breaks every rule above. Test it.
- Different details per mailbox. If you send from several domains, every one must point to the same, real legal entity.
- Agency sends without client details. If an agency sends on your behalf, the email must identify you, the company on whose behalf it is sent, not just the agency.
How Outvori does it
Outvori adds a one-line sender identity (legal company name, optional registration number and postal address) above the unsubscribe link in every campaign email, in the language of the email, and adds the one-click unsubscribe headers. A campaign cannot go live until the sender identity is saved, so nothing is ever sent without it. See cold email, and for sending volume read how many cold emails per mailbox per day.
