AU Cold Outreach (Spam Act compliant)

When to use

Triggers:

• "Write cold emails for [segment]" / "Draft a B2B outreach sequence"
• "Help me with cold email" / "Set up outbound"
• "Is this email legal in Australia?" / "Spam Act compliance for my sequence"
• Any AU SME wanting B2B outreach with a legal / risk-aware approach

Don't fire for:

• B2C marketing (different consent rules, often express only)
• Transactional emails (receipts, confirmations — Spam Act carve-out)
• Existing-customer nurture (different rules — usually covered by inferred consent from the prior relationship)

The Spam Act 2003 in 90 seconds (AU context)

The Australian framework (enforced by ACMA) has three pillars:

1. Consent. Either express (they opted in) or inferred (prior relationship, or the email address is conspicuously published for business purposes).
2. Identification. Every email clearly identifies the sender (legal name + contactable address, not just a reply-to).
3. Unsubscribe. A functional opt-out mechanism; must work for at least 30 days; unsubscribes honoured within 5 business days.

Penalties: up to $2.2M AUD per day for serious or repeated breaches. The burden of proof that you had consent is on the sender — so records matter.

Inferred consent is the key difference from CASL (Canada) and makes AU B2B cold email workable. But "inferred" has limits. You can't infer consent from:

• A personal Gmail / Hotmail / Outlook address
• A generic info@ / sales@ address if the business owner hasn't published it for the specific purpose you're emailing about
• A LinkedIn profile unless the address is listed in the profile's public contact fields
• A scraped list from a broker — "this address was on a database" is not inferred consent

Inferred consent you can rely on:

• The specific individual's work email listed on their company's website, adjacent to their role, in a context relevant to your outreach (e.g. a GM of Operations emailing a CFO about operations software)
• An email published in a directory / association membership list in the context relevant to your outreach
• A prior genuine interaction (conference, webinar, mutual connection) that the recipient would recognise

Workflow

Step 1 — Target definition + consent audit

Before drafting a single message, lock down:

1. Target segment. Specific: "Independent Australian accounting firms with 3–20 staff, serving SME clients, with a public email for the principal or office manager".
2. Consent model per prospect type. For each source, classify:
   • Express (they gave you the email for this purpose)
   • Inferred — strong (individual email + relevant public context)
   • Inferred — weak (generic mailbox, role-based, tangentially relevant)
   • No consent (scraped, unrelated)

Only emails in the first three categories go into the sequence. No-consent prospects get nothing.

3. Record the consent basis per prospect. One column on the list: consent_type | source_url | source_date. This is your burden-of-proof record.

Step 2 — Sequence design (4 touches)

Standard AU B2B cold sequence:

Touch 1 — Connection (Day 0)

• Opens with a specific hook tied to the prospect's public context (not "I saw your company online")
• Frames the sender's relevance in one sentence
• A small, soft question — not a meeting CTA
• Clear sender identification
• Unsubscribe link at the foot, plus legal name + physical address (even if PO Box)
• Target length: 60–90 words

Touch 2 — Value touch (Day 3)

• References Touch 1 without guilt-tripping ("following up" is fine, "I haven't heard back" is not)
• Adds one piece of genuine value (resource, observation, data point specific to their world)
• No ask at all, or the same small question
• Target length: 70–100 words

Touch 3 — Light CTA (Day 7)

• Only now introduces a meeting / call CTA
• Offers two concrete times OR a scheduler link — not both
• Acknowledges a "no" gracefully and offers a gentler alternative
• Target length: 60–80 words

Touch 4 — Graceful close (Day 14)

• "Last email from me unless you'd like to continue"
• No manipulative last-chance framing
• Leaves the door open for future outreach after 6+ months
• Target length: 40–60 words

Step 3 — Every-email compliance checklist

Every individual send, regardless of touch number, must include:

☐ Sender legal name (not a brand, a legal entity)
☐ Sender ABN (optional but strong)
☐ Sender physical address (can be a PO Box)
☐ Sender email identity consistent across the sequence
☐ Unsubscribe link (plain-text or HTML) — functional for 30+ days
☐ Unsubscribe mechanism in place: ≤ 5 business days to remove
☐ No deceptive subject line
☐ No deceptive "from" name
☐ Consent basis recorded on the list for this recipient
☐ Suppression list checked (don't email past-unsubscribers)

If any box is unticked, don't send.

Step 4 — Subject line guidance

Good AU B2B cold subject lines share traits:

• Specific, not salesy
• Mention either the prospect's context or a tangible value — not both
• 5–9 words, lowercase
• Natural — a human would actually write this to a stranger

Good examples:

• Quick thought on [specific thing they do]
• [Prospect's competitor/peer] mentioned [topic]
• 3 min question on [specific workflow]

Prohibited:

• ALL CAPS
• FREE / URGENT / LIMITED TIME / ACT NOW
• Fake re: or fwd: prefixes
• Emoji in the subject (noise; some spam filters weight against)

Step 5 — Copy patterns by segment

Different segments respond to different framings. Rough defaults:

| Segment | Opener pattern | CTA pattern | |---|---|---| | Professional services (accountants, lawyers, consultants) | Specific observation about their practice | "Worth 15 min to compare notes?" | | Trades / construction | Direct mention of an operational pain | "Want to see how [peer] does it?" | | Healthcare / NDIS | Compliance or documentation angle | "Happy to send a 1-pager — interested?" | | Hospitality | Seasonal / event-specific angle | "Keen to explore if it fits your Q[X]?" | | Tech / SaaS founders | Technical detail, not business speak | "Fancy a 20-min architecture convo?" | | Retail / ecommerce | Revenue or conversion angle | "Want the numbers on how [peer] moved the needle?" |

Don't use "I help [industry] with AI" openers. Don't use "What if I told you..." Don't use synthetic urgency.

Output format

For each campaign, produce:

1. Sequence document — 4 email drafts (Touch 1–4), with merge tags for personalisation
2. Compliance checklist — one-page PDF / markdown, tick-and-sign format, kept with the campaign's audit trail
3. List prep CSV — columns: email, first_name, last_name, company, role, consent_type, source_url, source_date, touch_1_sent, touch_2_sent, ...
4. Subject line bank — 5 variants per touch for A/B testing
5. Escalation paths — if a prospect replies positively, what happens next (handoff to the operator, next-step sequence, etc.)

Record-keeping requirements

For every send, keep:

• Timestamp of send
• Recipient email
• Template version used
• Unsubscribe link used
• Consent basis (copied from the list)

Keep these records for at least 3 years. ACMA can and does request proof during investigations.

What this skill does NOT do

• Send the emails. Your ESP does (Mailchimp, ActiveCampaign, Brevo, HubSpot, Instantly, Smartlead, etc.). The skill produces the content + compliance metadata.
• Source the list. Your research workflow does. The skill does not scrape, purchase, or enrich lists.
• Manage deliverability. Domain warming, SPF/DKIM/DMARC, IP reputation — separate concerns.
• Legal sign-off. For anything contentious — targeting regulated industries, claims that could be challenged, high-volume campaigns to large lists — have a privacy or commercial lawyer review before sending.

Tier access

Base. Cold outreach is a core growth lever for most AU SMEs. The skill is intentionally accessible — and the compliance piece is risk-reducing rather than scope-expanding. Pro-tier members get the additional variant-by-segment library; Partner-tier members get a review cycle on their actual sequences before send.

Related skills

• thl-linkedin-outreach-personaliser (internal, admin-only) — different channel, tighter voice rules
• seo-audit — complementary inbound workflow
• claude-4-7-extended-thinking-for-sme — use extended thinking for "should I email this prospect or not" edge cases on consent

References

• ACMA — Spam Act 2003
• Thomson Reuters — Spam Act 2003 Guide
• Sprintlaw — Email Marketing Laws in Australia (2026)
• DLA Piper — E-marketing expectations