Outbound Atlas

Atlas/The law/The platform's own exposure

Provider rules: Google, Microsoft and the ESPs

Google and Microsoft ban unsolicited mass email on paper but police it by volume and complaint metrics; SendGrid, Mailgun, SES and Postmark ban cold lists outright and can demand proof of consent, which is why cold email runs on mailboxes, not ESPs.

Lawhigh confidence8 minupdated 2026-10-0512 sources
Jurisdiction
Contractual (global)
Regime
n/a
Cold B2B email
Prohibited as 'unsolicited mass email' by every provider's policy; tolerated by Google and Microsoft below their metric thresholds
Penalty
Throttling, sending blocks, account or tenant suspension; no refund for AUP breaches
Enforced by
Private: provider trust & safety and abuse teams

All of the infrastructure cold email runs on prohibits cold email in its terms. Google's acceptable use policy bars use "to generate, distribute, publish or facilitate unsolicited mass email, promotions, advertisements, or other solicitations ("spam")" (last modified 13 October 2025). Microsoft's online-services AUP bars use "to spam" and calls bulk email "not a supported use of the service... permitted only on a 'best-effort' basis". The ESPs are stricter still.

The industry survives on the gap between what the policies say and what the providers enforce. Google and Microsoft enforce by metrics: per-mailbox volume caps, complaint rates, bounce rates and sending-pattern detection. They do not ask who consented. The transactional ESPs enforce by list provenance: they forbid purchased and scraped lists outright and, in Twilio's case, require proof of consent on demand. That difference explains the market's architecture: hundreds of cheap mailboxes rotated by a sequencer (Inbox rotation, Google vs Microsoft vs SMTP), not one ESP account.

So what

Cold email depends on the providers continuing to enforce metrics rather than rules. If Google or Microsoft began acting on their own AUP wording ("unsolicited mass email") with consent checks, the mailbox-farm model would break. That one variable is the sector's existential risk (Provider crackdowns, Kill criteria).

Google Workspace

RuleDetail (as of October 2026)Source
AUPNo "unsolicited mass email, promotions, advertisements, or other solicitations"AUP
SuspensionNotice, then 24 hours to cure an AUP violation; immediate for security/legal issuesTerms, modified 2 Sep 2026
ResellersServices bought through unaffiliated resellers are still governed by Google's termsTerms
Daily cap2,000 messages per user per day; 1,500 via mail merge; 500 on trial accountsSending limits
Trial gateLimits rise only once the domain has cumulatively paid at least $100Sending limits
Breach of capError, then no new messages for up to 24 hoursSending limits

The 2,000-a-day cap is far above what cold emailers send per mailbox. Practitioners run a few dozen per inbox per day for deliverability, not legal, reasons (Volume math: what 10k and 100k emails a day cost, Sending limits and throttling). So the binding constraint is Gmail's receiving-side filtering and the 2024 bulk-sender rules (Google and Yahoo sender rules), not the Workspace contract.

The reseller clause matters for the infrastructure layer. Vendors such as Mailforge, Zapmail, Maildoso and Scaledmail sell pre-provisioned Workspace or Microsoft inboxes. Their customers are bound by Google's AUP like anyone else, and the reseller relationship gives no protection.

Gap in the record

We could not verify reports of Google acting specifically against reseller-provisioned cold-email inboxes, or against particular reseller partners, in 2025–2026. If that is happening it is the most important fact on this page. See Provider crackdowns.

Microsoft 365 / Exchange Online

RuleDetail (as of October 2026)Source
AUPNo use "to spam"Universal license terms
Recipient rate10,000 recipients per mailbox per dayExchange Online limits
Message rate30 messages per minute; Exchange Online "is not suited for bulk-mailing scenarios"Exchange Online limits
Tenant cap (TERRL)External recipients per tenant per day scale with licence count; trial tenants capped at 5,000Exchange Online limits
onmicrosoft.com cap100 external recipients per organisation per 24 hours from the default MOERA domain; NDR 550 5.7.236Exchange Online limits
Outbound spamSuspected spam routed via a "high-risk delivery pool"; accounts and tenants that exceed limits are blocked ("restricted entities")Outbound spam protection
Bulk guidanceUse third-party bulk providers or Azure Communication ServicesExchange Online limits

Microsoft has more explicit structural controls than Google. The tenant-level external-recipient cap (TERRL) ties volume to paid licences, and the 100-recipient cap on onmicrosoft.com domains ends the trick of sending from default tenant domains. Both show Microsoft treating tenants as the abuse unit. Cold-email infrastructure vendors who pack many sending mailboxes into one tenant are betting against that unit.

Not verified

Microsoft's earlier plan for a per-mailbox External Recipient Rate limit of 2,000 per day does not appear on the Exchange Online limits page as of October 2026. Microsoft cancelled it on January 6, 2026, while promising unspecified "adaptive" limits with no date. See Microsoft rules: Outlook.com and Microsoft 365 limits.

Transactional ESPs: why cold email can't use them

ProviderPolicy (date)Key wordingEnforcement trigger
Twilio SendGridEmail Policy, updated 9 Apr 2026Bans "purchased or rented email lists" and addresses "obtained from the Internet or social media" without prior affirmative consent; bans snowshoeing and waterfalling; you must "promptly provide proof" of consentConsent proof on request; AUP termination (source)
Mailgun (Sinch)AUP, updated 16 Jan 2023Lists "bought, rented or scraped from third-parties... absolutely prohibited"; consent must be "clear, explicit and provable"Limit, suspend, terminate; no service credits (source)
Amazon SESAWS AUP + SES docsNo "unsolicited mass email"; "Do not buy, rent, or share email addresses"Review at 5% bounce / 0.1% complaints; pause at 10% / 0.5% (source, AUP)
PostmarkTerms of service"Use of a list that has been purchased or rented from a third party is prohibited"; permission-based lists onlyComplaints < 0.1%, bounces < 10% (source)

Two features rule out cold email on these services regardless of policy wording. First, shared IP pools: one cold sender's complaints damage every other customer's delivery, so the ESPs police list quality aggressively. Second, the metric thresholds: cold lists bounce and draw complaints at rates that trip SES's 5% bounce review or the 0.1% complaint lines quickly, even with verification (Email verification, Reply benchmarks). Twilio's April 2026 policy goes furthest. Scraped addresses are named explicitly, and consent must be provable on request. That is a contractual version of the CASL and Australian evidence test (Canada: CASL, Australia, New Zealand and APAC).

Note

Some cold-email platforms send through their own SMTP or private IP infrastructure instead of Google or Microsoft mailboxes (Sending architecture, ESP matching). That avoids the ESP bans but makes the platform the abuse desk, with the duties described on Platform liability: what the sequencer itself risks.

What they say vs. what they enforce

ProviderSaysEnforces
GoogleNo unsolicited mass emailVolume caps, complaint rate (bulk-sender rules), behavioural filtering; consent not checked
MicrosoftNo spam; bulk is unsupportedRecipient caps per mailbox and tenant, MOERA cap, outbound spam filtering, tenant blocks
SendGrid / Mailgun / SES / PostmarkNo purchased, rented or scraped lists; consent requiredBounce and complaint thresholds; consent proof on request (Twilio); manual review

What this means for an entrant

  • Build for the metric that gets mailboxes killed, and self-police before the provider does. Track per-mailbox and per-tenant complaint proxies, bounce rates and volume against Google and Microsoft thresholds. Pause automatically before the provider does it for you. A platform whose customers rarely lose mailboxes has a retention story incumbents struggle to match. See Bounce protection and Inbox placement testing.
  • Design tenant-aware infrastructure for Microsoft. TERRL and the onmicrosoft.com cap mean volume per tenant, not just per mailbox, is what Microsoft constrains. Spread sending across properly licensed tenants with custom domains, and show customers their tenant headroom. See Infrastructure strategy: build or partner.
  • Compliance as a feature can open better infrastructure. If a platform records per-lead provenance and a legal basis (see Cold email law: the jurisdiction matrix), it can produce the "proof of consent" or legitimate-interest record that Twilio-style policies ask for. That will not make cold email acceptable to SendGrid, but it puts the platform on the right side of the line if providers ever move from metric enforcement to rule enforcement.
  • Price in provider risk. Every cold-email business depends on Google and Microsoft tolerating behaviour their AUPs prohibit. Use multiple providers, keep a path to platform-operated SMTP, and set kill criteria (Kill criteria) tied to provider policy changes.
  • Don't resell Workspace or Microsoft seats as "cold email inboxes". The reseller clause gives no protection, and marketing a provider's product explicitly for an AUP-prohibited use is the easiest pattern for that provider to act against.
12 sources cited on this page · 10 domains
  1. unsolicited mass email, promotions, advertisements, or other solicitations (spam) workspace.google.com
  2. to spam microsoft.com
  3. not a supported use of the service... permitted only on a 'best-effort' basis learn.microsoft.com
  4. Terms, modified 2 Sep 2026 workspace.google.com
  5. Sending limits knowledge.workspace.google.com
  6. Exchange Online limits learn.microsoft.com
  7. cancelled it on January 6, 2026 office365itpros.com
  8. source twilio.com
  9. source mailgun.com
  10. source docs.aws.amazon.com
  11. AUP aws.amazon.com
  12. source postmarkapp.com