Can you cold email businesses in Spain?
Spain's LSSI article 21 bans unsolicited commercial email, business addresses included. The one exception, the fines, and what to do instead.
The short answer
No, with one narrow exception.
Spain's law on electronic commerce, Ley 34/2002 (the LSSI), prohibits sending advertising or promotional communications by email, or by an equivalent electronic means, unless the recipients requested them beforehand or expressly authorised them. That is article 21.1, and the Spanish text reads: "Queda prohibido el envío de comunicaciones publicitarias o promocionales por correo electrónico u otro medio de comunicación electrónica equivalente que previamente no hubieran sido solicitadas o expresamente autorizadas por los destinatarios de las mismas". You can read the consolidated law on the official BOE site.
So when people ask whether you can cold email businesses in Spain, the honest answer is that the law asks for permission first, and a cold email by definition does not have it.
This article explains the rule and what we do about it. It is not legal advice, and if you have a real case in front of you, a Spanish lawyer is the right person to ask
"But it's a business address"
This is the part that surprises people who are used to other countries' rules.
Article 21 speaks of recipients — destinatarios — and does not make an exception for business recipients. A company's address is covered as well as a consumer's.
So an info@ address, a sales@ address, a named buyer at a Spanish firm: the same rule applies. The fact that the person on the other end reads that mailbox for work does not move them out of article 21.
The one exception: a prior contractual relationship
Article 21.2 allows one case: a prior contractual relationship, where the sender obtained the contact details lawfully and writes about its own products or services similar to those the customer originally contracted.
That is narrower than it first sounds. The details have to have been collected lawfully in the course of that relationship, and what you send has to be similar to what the customer already bought from you. A conversation that never became a sale is not a prior contractual relationship
Even inside the exception, there are conditions. The recipient must be offered a simple, free way to object, both at the moment the details are collected and in every commercial email you send. Every such email must include a valid email address where that right can be exercised. And a recipient may withdraw consent at any time simply by telling you, under article 22.1.
So the exception covers writing to your own existing customers about more of what they already bought. It does not cover finding new ones.
Two more rules that travel with any commercial email
Article 20.1 says a commercial communication sent electronically must be clearly identifiable as such, and so must the person or company on whose behalf it is sent. No disguising an advert as something else, and no hiding who is behind it.
Article 22.1 gives the recipient the right to withdraw consent at any time, just by telling the sender. Permission given once is not permission for ever.
What it costs if you get it wrong
The LSSI puts numbers on it.
Sending commercial emails in bulk, or insistently or systematically to the same recipient, without meeting article 21, is a serious infringement — an infracción grave — under article 38.3 c). Any other commercial email sent without meeting article 21 is a minor infringement, an infracción leve, under article 38.4 d).
Article 39.1 sets the fines: a serious infringement is fined from 30,001 to 150,000 euros, and a minor infringement up to 30,000 euros.
That is the spread. One stray email sits at the minor end; a list upload and a sequence that chases the same person sits at the serious end.
Why Joogoos will not send a cold letter to a Spanish company
Joogoos's Customers finds companies that could buy from a business and drafts introduction letters to them, sent from the business's own mailbox. Before any letter, it checks the law of the company's country, from a table written into Joogoos's code with the rule each row was read from.
It is not a setting. There is no screen and no workspace that can switch it off.
A country either lets letters go or holds them. Spain holds: Spain's law wants permission before a commercial email is sent, under LSSI-CE article 21, so no cold letter goes to a Spanish company. Saudi Arabia and Tunisia hold too. A country nobody has read yet holds until somebody reads its law.
We say it before anything is paid for. Joogoos does not pay for an opening line for a letter that can never leave, the company's screen says why in words, and an imported list tells you how many of its companies are held before the import runs.
The reason is the one above: the fine for getting this wrong lands on the business whose mailbox the letter went out from
A held company is not a deleted company
The law refuses an unsolicited email. It does not refuse knowing who a company is.
So a Spanish company can still be found, imported, read and judged in Joogoos, and it can be reached by an introduction or a phone call. Only the letter is refused.
That matters more than it sounds. The research is the slow part of finding new customers, and that part still works for Spain What changes is how you make first contact
What to do instead
If the Spanish market is where your customers are, you need a first contact that is not an unsolicited commercial email.
Pick up the phone. A held company in Joogoos can still be reached by a phone call. You will have the research in front of you when you dial.
Get the introduction. A warm introduction from someone who already works with them is not a commercial email sent cold Trade bodies, suppliers you share, and customers who sell into Spain are the usual routes
Ask for permission first, by another channel. Article 21 is about what was requested or expressly authorised beforehand. If a buyer asks you to send details after a call or a meeting, you are on a different footing. Keep a record of when and how they asked
Let them come to you. Articles on your own site that answer the questions your buyers type into Google do not need anyone's prior authorisation If that is new ground, our piece on getting found on Google without hiring an agency walks through what to write and why it works.
Spend the effort where letters do go. Most countries in Joogoos's table let letters go, and the same research and the same letter work there. If you want to sharpen what you send, we have written about what belongs in an introduction letter to a business, from the first line to the ask.
The rule of thumb
Spain asks for permission before a commercial email goes out, and a business address does not change that. The exception is your own past customers, for similar things, with an easy way to say stop. Everything else is a phone call, an introduction, or a reason for them to write to you first
Joogoos writes the introduction letters to the companies that could become your customers, checks the law of each company's country before it drafts anything, and charges as you go rather than monthly. If you want to see what that looks like for your own business, get in touch and tell us what you sell
Questions
Is it legal to cold email a company's info@ address in Spain?
No. Article 21.1 of the LSSI prohibits advertising or promotional email that the recipient did not request beforehand or expressly authorise. The article speaks of recipients and makes no exception for business recipients, so a company address is covered as well as a consumer's.
What is the fine for sending unsolicited commercial email in Spain?
Sending commercial emails in bulk, or insistently or systematically to the same recipient, without meeting article 21 is a serious infringement, fined from 30,001 to 150,000 euros. Any other commercial email that does not meet article 21 is a minor infringement, fined up to 30,000 euros.
Can I email a Spanish company I have already sold to?
That is the one exception in article 21.2: a prior contractual relationship, where you obtained the contact details lawfully and write about your own products or services similar to the ones the customer originally contracted. Even then you must offer a simple, free way to object, both when the details are collected and in every commercial email, and include a valid email address where that right can be exercised.
Does the law apply if I am writing from outside Spain?
Article 21 is written around the recipients of the message rather than the sender's location. Whether Spanish authorities would pursue a sender based abroad is a question for a lawyer who handles LSSI cases
Can Joogoos be set to send to Spain anyway?
No. The country check runs from a table written into Joogoos's code with the rule each row was read from, and it is not a setting — no screen and no workspace can switch it. Spain holds, so no cold letter goes to a Spanish company.
Can I still research and keep Spanish companies in Joogoos?
Yes. A held company is still kept: it can be found, imported, read and judged, and reached by an introduction or a phone call. Only the letter is refused. Joogoos also tells you how many companies in an imported list are held before the import runs, and does not charge for an opening line for a letter that can never leave.