CAN-SPAM: Header Accuracy Requirements
Header Accuracy Requirements [15 U.S.C. § 7704(a)(1)]
Rule: Email header information must be accurate and not misleading. This is the most strictly enforced CAN-SPAM provision.
Header Elements Covered
| Element | Requirement | Example Violation |
|---|---|---|
| From | Must accurately identify sender | Using fake sender name |
| To | Must be valid recipient | Forged recipient headers |
| Reply-To | Must be functional | Non-working reply address |
| Routing info | Must not be falsified | Spoofed originating domain |
| Originating domain | Must be legitimate | Using hijacked domain |
Source Text
(1) Prohibition of false or misleading transmission information
It is unlawful for any person to initiate the transmission, to a protected computer, of a commercial electronic mail message, or a transactional or relationship message, that contains, or is accompanied by, header information that is materially false or materially misleading.
Key Points
“Materially false or misleading” means:
- Header would deceive a reasonable recipient about the origin or transmission path
- Includes technically accurate headers that create a false impression
Applies to ALL emails:
- Unlike most CAN-SPAM provisions, header accuracy applies to BOTH commercial AND transactional emails
- There is no exemption for relationship messages
Practical Guidance
- From name: Can be brand name, but must accurately represent who is sending
- From address: Domain must be controlled by the sender
- Reply-To: Must go to an address the sender monitors
- Using ESPs: You’re still liable even if your email service provider handles technical sending