Guide
Cold email or cold calling in the Baltics.
What the law allows in Lithuania, Latvia, Estonia and Finland, what changed in Lithuania in 2026, and which channel actually reaches which buyer.
The legal position, country by country
Two different rules are in play. The GDPR governs the personal data you process, including a named person's work email address. The ePrivacy Directive, implemented nationally, governs unsolicited electronic marketing. Member states were left free to decide whether legal persons get the same protection as individuals, and they decided differently.
| Country | B2B email to a legal person | Live phone call to a business number | Automated calls |
|---|---|---|---|
| Lithuania | Opt-out since 22 April 2026. Article 81 of the Law on Electronic Communications now says prior consent is not required where the subscriber is a legal person, provided it is given a clear, free and easily exercised way to refuse further direct marketing. | No prior consent needed | Consent required |
| Latvia | Opt-out for legal persons | No prior consent needed | Consent required |
| Estonia | Opt-out for legal persons | No prior consent needed | Consent required |
| Finland | Opt-out for legal persons, but the strictest of the four when you write to a named individual at their work address, where the test is whether the message relates to that person's role | No prior consent needed | Consent required |
The Lithuanian rule, from the statute itself. Law No. XV-815 of 16 April 2026 replaced Article 81 of the Law on Electronic Communications. Article 10 of that act is the direct marketing amendment, and Article 14 brought Article 10 into force on 22 April 2026, ahead of the rest of the act, which commenced on 1 July 2026. The new Article 81(1) requires prior consent for direct marketing by electronic communications, then says: such consent is not required where the subscriber or registered user is a legal person, but that person must be given a clear, free and easily exercised opportunity to refuse further use of its contact details for direct marketing.
Read on the Register of Legal Acts, 20 September 2026. Published in TAR on 21 April 2026, No. 2026-06393. General information, not legal advice.
What opt-out does not mean. It does not remove the GDPR. A named person's work email is personal data. You still need a lawful basis, which in practice is legitimate interest, you still owe transparency, and you still have to honour objections. In practice that means: a real sender, a real company, a working opt-out, a suppression list that is permanent, and a record of where the address came from.
Which channel reaches which buyer
Anybody quoting you response rates for this region without naming the segment is inventing them. What is observably true is the shape of it.
- Email works where the buyer is under fifty, works at a desk, has a personal work address that is published or inferable, and operates in a sector used to being approached: software, professional services, logistics, marketing, finance.
- The phone works where the buyer is a plant manager, technical director, production head or procurement lead at a mid-sized manufacturer, where the published address is a general info mailbox, and where the company's website was last updated in 2019. This describes a very large part of the Baltic industrial base.
- Language decides more than channel. An English email to a Lithuanian production director gets read. A Lithuanian call gets answered. In Finland, Finnish is not optional for the phone.
- LinkedIn is thin here outside technology and professional services. Do not build a campaign on it for industrial buyers.
The sequence that works in practice
Email first, for ten days
It is cheap and it sorts the list. Four steps over about three weeks, from a separate sending domain, never your main one.
Call the silence
Everyone who engaged but did not reply, and everyone whose only address was a general mailbox, goes to the phone with a written reason to call.
Keep one suppression list across everything
An opt-out on email suppresses the phone too. Permanently, and across every principal, not for ninety days.
Cap the volume
Low daily sends per mailbox, automatic pause above a two percent bounce rate, and no contact worked twice in a month. Volume is what turns outreach into spam, and spam is what kills a sending domain you will need for years.
Practical compliance checklist
- Identify the sender and the company clearly in every message
- Include a working, one-click, free opt-out in every message
- Keep the source of every address on record
- Honour objections immediately and permanently
- Do not use automated or pre-recorded calls
- Keep a written record of the legitimate interest assessment
- Publish a privacy notice that a recipient can actually reach
The national supervisory authorities are the State Data Protection Inspectorate in Lithuania, the Data State Inspectorate in Latvia, the Data Protection Inspectorate in Estonia and the Office of the Data Protection Ombudsman in Finland. Their guidance is the thing to read before a campaign, not after one.
Sources
Every figure on this page comes from one of these, read on the date shown. Where a source could not be reached directly, the page says so rather than implying a check that did not happen.
- Law amending the Lithuanian Law on Electronic Communications, No. XV-815 — adopted 16 April 2026, Article 10 in force 22 April 2026, read in the Register of Legal Acts
- State Data Protection Inspectorate of Lithuania — the supervisory authority for Lithuania
- Data State Inspectorate of Latvia
- Estonian Data Protection Inspectorate
- Office of the Data Protection Ombudsman, Finland — the strictest of the four on messages to a named person at work
- ePrivacy Directive 2002/58/EC — Article 13 on unsolicited communications, and the member state option on legal persons
- General Data Protection Regulation — legitimate interest, transparency and the right to object
Read 20 to 22 September 2026.
Last reviewed 2026-09-22. Written by Arūnas Roličius, get2market, Vilnius. Figures are dated where they are quoted.