Protecting Legitimate Small-Business Email in Canada
Ensuring fair access to essential communication tools without enabling spam.

This letter has been sent to Canadian regulatory bodies after encountering a problem shared by many small businesses: legitimate email being blocked with no realisitc recourse.

As a provider working to build secure, abuse resistant email systems for small organizations, I belive the solution must protect users without excluding honest participants who follow best practices.

To whom it may concern,

I am writing as an independent technology provider operating entirely within Canada. Recently, we encountered a problem that illustrates a broader issue affecting small businesses and innovators across the country: it has become practically impossible to operate a legitimate, Canadian-hosted email service without the cooperation - and implicit approval - of a handful of corporations who control email filtering.

Today, major mailbox providers (including Microsoft, Google, and large Canadian ISPs) act simultaneously as gatekeepers of email delivery and commercial providers of competing email services. Their automated blocking systems require no public evidence, provide no transparent criteria, and offer no practical process for timely review. A small business can comply fully with technical standards, operate responsibly, and still be rejected without explanation or recourse.

To illustrate the impact: a new server using a clean IP address may be automatically blocked despite meeting all published requirements (DNS, SPF, DKIM, DMARC, reverse DNS, no history of abuse, etc.). The operator is then required to "warm up" reputationally - but cannot do so, because blocking prevents warm-up from happening. This creates a closed loop in which access to the market can be denied indefinitely by competitors without any formal decision, oversight, or appeal mechanism.

As a practical example, I recently deployed a contact system for a Canadian business specifically to reduce spam exposure. Ironically, because there is no recognized path for a legitimate new server to establish trust, the very system designed to protect the business is treated as if it were the spam we were trying to prevent. The result is a situation where spam is delivered, but legitimate communication is delayed or silently rejected without recourse.

This is not a matter of spam control; sound anti-abuse measures are essential. The problem is that email filtering has become an opaque barrier to market entry, with no due-process safeguard for legitimate providers, startups, or small businesses. A handful of corporations now determine who may or may not participate in an entire communications market-informally, automatically, and without regulatory accountability.

Given that Canada already regulates telecommunications and internet service obligations, it appears reasonable to request:

1. A standardized, fair, and time-bound appeals process for email blocking, applicable to all providers that serve Canadian customers.
2. Publicly documented criteria for email acceptance, including an explicit path for new providers to establish a compliance history.
3. Separation of anti-abuse filtering from commercial incentives, similar to existing expectations in other regulated industries (e.g., telecom routing, phone number portability).
4. A formal requirement that ISPs and mailbox providers recognize valid evidence of Canadian network ownership for reputation transfer when IP space changes hands.

This approach would not interfere with spam mitigation. Instead, it would ensure that spam controls cannot unintentionally function as de-facto gatekeeping. Right now, the absence of due process means legitimate businesses may be blocked not for abuse, but simply because they are new - a situation that favors incumbent providers over Canadian innovators.

I respectfully request consultation or guidance on whether CRTC or another appropriate agency may consider regulatory safeguards to protect fair access to email delivery within Canada.

Thank you for your time and consideration. I would welcome the opportunity to provide technical examples and documentation, if useful.

Sincerely,

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Tyler Anderson
SineLabs LTD.