Corporate vs individual subscribers under PECR

Under PECR, a corporate subscriber is a body corporate (a limited company, a PLC, an LLP, a Scottish partnership, some government bodies and other incorporated bodies). Everyone else is an individual subscriber, including consumers, sole traders and other partnerships. The difference matters because the regulation 22 consent rule for marketing emails applies to individual subscribers but not to corporate ones. If you cannot tell which one an address belongs to, guidance from the ICO (now the Information Commission) says to treat it as an individual.

Why the distinction exists

The Privacy and Electronic Communications Regulations 2003 protect subscribers, meaning the person or organisation that holds the account with the communications provider. Parliament gave individuals stronger protection than incorporated organisations. Individuals must opt in to marketing emails (or fall under the soft opt-in); bodies corporate can be emailed without consent, provided the sender identifies itself and offers an opt-out.

The ICO (the Information Commission since 30 September 2026) sets this out in its business to business marketing guidance. That page carries a notice saying it is under review following the Data (Use and Access) Act 2025, so its wording may change. The rule itself has not.

Corporate subscribers

According to ICO guidance, corporate subscribers include:

• companies, including private limited companies and PLCs;
• limited liability partnerships (LLPs);
• Scottish partnerships, which have legal personality;
• some government bodies;
• other bodies corporate.

What these have in common is legal personality separate from the people who run them. You can check that on the Companies House register, which records company type and status.

Individual subscribers

Individual subscribers include:

• anyone using a personal address, such as Gmail, Outlook, iCloud or an internet provider mailbox;
• sole traders, whatever their trading name or domain;
• partnerships other than LLPs and Scottish partnerships, such as ordinary partnerships in England, Wales and Northern Ireland.

A sole trader on a smart looking domain is still an individual subscriber. So is a partner in an unincorporated firm. Our guide to sole traders and partnerships covers this in more detail.

When you are not sure

ICO guidance is direct: if you are unsure whether contact details belong to a corporate or an individual subscriber, treat them as an individual subscriber. In practice the uncertain cases are common:

• a domain that matches no UK registered company;
• several possible companies for one domain;
• a company that has been dissolved or is in liquidation;
• a shared or hosting domain used by many unrelated businesses;
• a domain registered outside the UK.

PECR Check returns UNKNOWN with the recommended action CONSENT_REQUIRED for all of these, with reason codes such as NO_UK_MATCH, MULTIPLE_CANDIDATES, COMPANY_DISSOLVED or SHARED_OR_HOSTING_DOMAIN so you can see why.

How PECR Check classifies an address

For each email address, PECR Check:

1. checks the address is deliverable (syntax, mail servers, mailbox, disposable and role accounts);
2. screens free webmail and consumer ISP domains and returns INDIVIDUAL_SUBSCRIBER straight away;
3. identifies the organisation behind a business domain using Emailmovers’ UK business data and Companies House;
4. returns the company name, number, type and status, a verdict, a recommended action, a confidence score and reason codes.

Only a confident match to an active UK body corporate returns CORPORATE_SUBSCRIBER. A match below your confidence threshold (0.85 by default) is downgraded to UNKNOWN with the reason LOW_CONFIDENCE_MATCH.

Corporate does not mean anything goes

A corporate subscriber verdict tells you the reg 22 consent rule does not apply. It does not remove the duty to identify yourself and give an opt-out under reg 23, or your UK GDPR duties to the named person behind a work address: a lawful basis, privacy information and the right to object. PECR Check is a classification with evidence, not legal advice.