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Does Mailgun Allow Cold Email? Policy and Risks

Does Mailgun Allow Cold Email? Policy and Risks

BulkEmailSetup
BulkEmailSetup Team
November 12, 2026
6 min read

No, Mailgun does not allow cold email. Its acceptable use policy only permits marketing email to people who gave clear, explicit and provable consent through a confirmed opt-in, and it bans bought, rented and scraped lists outright. On top of that it caps spam complaints at 0.08% and bounces at 5%. Cold outreach fails the consent rule before the numbers even come into it, so if outreach is your use case, plan to send it from somewhere else.

What Mailgun's policy actually says

The policy was last revised on January 16, 2023 and applies across Sinch Email, the group Mailgun belongs to. These are the parts that decide cold email.

Policy sectionWhat it saysWhat it means for outreach
1b, listsbought, rented or scraped lists are "absolutely prohibited"prospect lists from data vendors are out
1c, consentmarketing only to people with "clear, explicit and provable consent"a cold prospect has not opted in
1c, methodconsent through confirmed single or double opt-ina LinkedIn profile is not opt-in
1d, proofproof of consent required on an escalated complaintyou must show the signup record
1e, unsubscribea link in every marketing email, honoured without delayneeded anyway, by law
2a, lawno breaking laws on unsolicited commercial emailthe law is the floor, not the ceiling

The word "cold" never appears. It does not need to. Rule 1c on its own excludes anyone who did not ask to hear from you.

The numbers that pause an account

Even an opt-in sender has to stay inside these limits. Mailgun also says it can change them without notice.

MetricMailgun limitOn a 10,000 email send
Spam complaints0.08% or less8 complaints
Bounces5% or less500 bounces
Unsubscribes1.4% or less (1% if unsubscribes beat clicks)140 unsubscribes
Blocksunder 20%2,000 blocked

Mailgun's spam complaint limit on a gauge A gauge from 0% to 0.4%. Mailgun pauses accounts above 0.08%, Gmail's ceiling is 0.3%, and a cold list at 3.5 reports per 1,000 sits at 0.35%, past both. Spam complaint rate Mailgun 0.08% Gmail 0.3% 0% 0.4% Cold list: 3.5 per 1,000 = 0.35% over Mailgun's line by more than 4 times Mailgun's complaint limit is a third of Gmail's 0.3% ceiling

That 0.08% line is tighter than Google's own 0.3% ceiling. Shared IPs explain why: your complaints land on the same addresses as other Mailgun customers, so Mailgun acts long before Gmail would. A cold list that gets 3 or 4 reports per thousand is five times over the line on day one.

Why outreach gets caught

Cold email shows up in Mailgun's data in three ways, usually within the first few sends.

  1. Bounces. Prospect lists decay fast. A list that is a year old can bounce 5% to 15%, which is over the 5% limit on its own.
  2. Complaints. People who never signed up press "report spam" far more than subscribers do.
  3. Spam traps. Scraped and bought lists carry recycled trap addresses. One hit is a strong signal the list was not opt-in.

Once a review starts, rule 1d applies: you are asked for proof of consent. For a cold list there is nothing to show, and the account is usually disabled.

What proof of consent looks like

If you do send opt-in mail through Mailgun, keep records that would pass a review. This is the bar a cold list cannot meet.

Consent records Mailgun can ask for Five records per address: signup date, source form, IP at signup, confirmation click and unsubscribe status. An opt-in subscriber has all five. A cold prospect has none. Proof of consent, per address Opt-in Cold Signup date Source form or page IP address at signup Confirmation click Unsubscribe status What a reviewer expects to see for each address

RecordOpt-in subscriberCold prospect
Signup date and sourceform on your site, timestampednone
Confirmation clickyes, for double opt-innone
IP at signuploggednone
Lawful basisconsentat best "legitimate interest", not accepted by Mailgun

Legal is not the same as allowed

Plenty of cold email is legal. In the US, the FTC's CAN-SPAM rules let you send commercial email without prior consent if headers and subject lines are honest, a postal address is included, and opt-outs are honoured within 10 business days. The UK and EU are stricter for individuals but allow some B2B outreach.

A provider's policy can still be tighter than the law, and Mailgun's is. It requires opt-in everywhere. So "is it legal?" and "will Mailgun let me?" have different answers, and only the second one decides whether your account survives.

Where cold outreach can go instead

The clean setup keeps outreach completely away from the account that sends your receipts and password resets.

Before and after: split outreach from transactional mail Before: outreach and password resets share one Mailgun account, so a complaint spike stops both. After: resets stay on Mailgun and outreach runs on its own server and domain. Before After Outreach Password resets One Mailgun account complaint spike both stop Outreach Password resets own server + domain Mailgun account one problem, one stream Split the streams so one complaint spike cannot stop your password resets

OptionCold outreach allowed?Risk
Mailgun shared IPsnoaccount disabled, transactional stops too
Mailgun dedicated IPno, same policysame policy applies, IP just costs more
SendGrid or Amazon SESnosee does SendGrid allow cold email and does SES allow it
Google Workspace inboxestolerated at low volumedaily caps, inbox suspensions
Your own SMTP server and IPsyour rules, the law still appliesyou own warm-up and list quality

For a wider list of options, see SMTP providers that actually allow cold email.

Rules that keep outreach on your own server healthy

Owning the IPs removes the policy problem. It does not remove the inbox providers.

  • Use a separate domain or subdomain for outreach, never the one your customers know.
  • Verify the list before every send. Keep bounces under 2%.
  • Send small, steady volumes per IP and domain. A few hundred a day per IP at first, ramping slowly. Our IP warm-up schedule has the weekly numbers.
  • Write to one person. Plain text, a real reason to contact them, an easy opt-out.
  • Watch complaints weekly. Gmail's 0.3% ceiling still applies to you.

How BulkEmailSetup helps

We set up a dedicated SMTP server you own, with your own IPs and sending domains, SPF, DKIM, DMARC and PTR configured, bounce handling, a campaign platform and a warm-up plan. Your outreach is judged on your own reputation, not on a shared pool's policy.

PlanOne-time feeEmails per dayDedicated IPsDomains
Basic$54925,00031
Advance$1,199200,000154

There is no monthly fee to us, only about $11 a month of hosting on Basic paid to your host, and a 15-day money-back guarantee. See Basic plan details or compare all pricing.

Outreach on BulkEmailSetup servers follows our anti-spam policy: lawful B2B email to business contacts you researched yourself, a working opt-out honoured within 10 business days, your physical address in every message, and complaints under 0.1%. Bought, rented or scraped lists are not allowed.

Frequently asked questions

Does Mailgun allow cold email?

No. Mailgun's acceptable use policy says marketing email can only go to recipients who gave clear, explicit and provable consent, collected through a confirmed single or double opt-in. A cold prospect has not opted in, so cold outreach breaks the policy even if it is legal where you are. Accounts sending it are usually disabled once complaints or bounces show up.

What does Mailgun's policy say about unsolicited email?

The policy, last revised January 16, 2023, bans breaking laws on unsolicited commercial email, bans bought, rented or scraped lists outright, and requires an unsubscribe link in every marketing email. It also says you must show proof of consent if an abuse complaint escalates. It does not use the words cold email, but the consent rule covers it.

Why does Mailgun disable accounts for outreach?

Because outreach trips Mailgun's published limits fast. The policy caps spam complaints at 0.08%, bounces at 5% and blocked messages under 20%. On a 10,000 email send, 8 complaints crosses the line. Cold lists bounce more and get reported more than opt-in lists, and on shared IPs that risk lands on other Mailgun customers, so the account gets paused.

Which SMTP providers allow cold outreach?

Most shared-IP providers, including Mailgun, SendGrid and Amazon SES, ban it or make it very risky. Cold outreach fits on infrastructure where only your reputation is at stake: your own dedicated SMTP server with your own IPs and sending domains, such as BulkEmailSetup's Basic plan at $549 one-time for 3 IPs and 25,000 a day. You still have to follow the law, such as CAN-SPAM in the US, and keep complaint and bounce rates low.

Is cold email legal even if Mailgun bans it?

Often yes. In the US, CAN-SPAM allows commercial email without prior consent if you use honest headers and subject lines, include a postal address and honour opt-outs within 10 business days. The EU and UK are stricter for individuals. A provider's policy can be tighter than the law, and Mailgun's is: it requires opt-in regardless of where you send.

Can I use Mailgun for transactional email and send outreach elsewhere?

Yes, and many teams do. Keep receipts, password resets and product mail on Mailgun, and run outreach from a separate sending domain on separate infrastructure. Never send outreach through the same Mailgun account or domain, because one complaint spike can pause the account that also carries your password resets.

What happens to my Mailgun account if I send cold email?

Typically the account is paused for review once complaints, bounces or blocks pass the thresholds, and you are asked to show proof of consent. If you cannot show opt-in records for the list, the account is usually disabled. Sending can stop mid-campaign, and transactional mail on the same account stops with it.

Tags

mailgun cold emailmailgun acceptable use policymailgun account disabledcold email smtpmailgun alternativesdedicated smtp serverb2b outreach
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