Can you legally call, text or email a homeowner lead in Ireland?

Contact a homeowner about what they asked for, keep proof of what they agreed to, and treat anything else as marketing, which brings the consent rules into play. This guide covers the Irish rules for calling, texting and emailing individuals, and what to record for every lead. It is practical guidance, not legal advice. For the wider picture, start with the EV charger installer guide.

Which Irish rules apply when you call, text or email a lead?

Two layers apply. According to the Data Protection Commission (DPC), the GDPR and the Data Protection Act 2018 cover most personal data processing, and the ePrivacy Regulations (S.I. 336/2011) add rules for electronic direct marketing by phone, fax, text message and email.

The Regulations count an SMS as electronic mail, so texts and emails follow the same rule. For unsolicited marketing to an individual, Regulation 13 works like this:

Source: S.I. No. 336/2011, Regulation 13, and DPC guidance on direct marketing, read November 2026.

Different rules apply to company recipients; this guide covers homeowners. Breaching Regulation 13 is a criminal offence, and each unsolicited call or message is a separate offence. On conviction on indictment, the fine can reach €250,000 for a company or €50,000 for an individual. Those figures come from the Regulations as made in 2011, so check the current text.

Is replying to a homeowner who asked for a quote the same as direct marketing?

Not automatically. The Regulations catch unsolicited communications, which they define as communications the person did not request. The DPC describes unsolicited contact as contact that was not sought. It says details volunteered in a survey or promotion may carry consent for later contact, depending on what the person knew and agreed to at the time. The same logic should apply to a quote form, but those are the DPC's examples, so read the form wording closely.

A homeowner who asked for quotes has requested contact about quotes, and that request sets the limit. A call about the quote is on safer ground than a pitch for another product, a newsletter or a call to a number they did not give. The DPC pages cited here do not settle whether a quote follow-up counts as marketing, so treat anything beyond answering the request as marketing until you have advice. The DPC says appointment reminders from a doctor, dentist or hairdresser are not direct marketing. Regulation 13(7) adds that an SMS sent for another purpose, such as a booking confirmation, needs consent if it includes marketing.

The GDPR applies either way. If you got the details from someone other than the homeowner, Article 14 requires you to say who you are, why you hold the details, the legal basis and where they came from, at the latest at first contact, unless the person already has that information. If your message is marketing, Article 21 adds that the right to object must be brought to their attention clearly at the latest in the first communication.

What did the DPC's 2024 prosecutions show about using third parties?

The DPC said controllers stay responsible for the processors they use. On 25 October 2024 the DPC announced the outcome of three prosecutions: Sky Ireland (texts), Google Ireland (phone calls) and Stella Novus (emails). Each company pleaded guilty to contacting a customer who had said they did not want it.

The DPC had warned each company earlier, in 2019 or 2023. The court directed each to give €1,500 to a charity and pay the DPC's costs, in lieu of a conviction and fine. All three used third-party processors, and the DPC said controllers "remain responsible for the actions of those processors". It added that before any electronic marketing, companies should be satisfied that their providers can ensure consent is valid and up to date and that opt-out mechanisms are fully functional.

Those cases concerned controllers and their processors, not installers buying from a supplier. How your arrangement with a supplier is classed is a legal question. The practical lesson carries over: do not assume the supplier's consent is good, and keep your own opt-out list.

What should a lead supplier be able to document about consent?

For each lead, the supplier should show when and where the homeowner agreed, the exact wording, and what it covered. Under the GDPR, consent must be freely given, specific, informed and unambiguous, given by a statement or clear affirmative action, and a controller relying on it must be able to demonstrate it. In a prosecution under Regulation 13, where consent is in issue, the defendant must show the person unambiguously consented.

Ask the supplier for:

• the date, time and page or form where the homeowner agreed
• the wording shown, including which channels (call, text, email) and which purpose it named
• whether it named your firm, or installers in general, and whether others can receive the same request
• how stop requests are passed on and how quickly

Smart Solar is a lead intermediary and installs nothing itself. The homeowner fills in the form and agrees that installers may contact them about quotes, and a request is not exclusive, so it can also go to other installers. Your own follow-up must still stay within what the homeowner agreed to. If you want to hear about working with us, sign up below.

Can you contact past customers about a charger, battery or service?

Only in limited cases without fresh consent. The DPC explains an exception for existing customers under Regulation 13(11). It covers email contact details lawfully obtained from a customer in a sale, and it applies only if all of these hold:

• you market your own product or service
• it is of a kind similar to what they bought
• the customer was clearly offered a chance to object when the details were collected, and is offered one in every message
• the first marketing message goes out within 12 months of the sale

The DPC says it does not cover a prospect who never buys; its example is a shopper who leaves before checkout. A quote that never became a job looks similar, so do not assume it qualifies. The Regulations define electronic mail to include SMS, so the exception should cover texts as well as emails. It does not appear in the rule for marketing calls to mobiles, which need consent.

Whether a charger is "similar" to the solar system you installed is a judgement call. If you want to sell to your own customers, see selling EV chargers to solar customers and heat pump replacement and service.

Checklist: what to record for every lead

Record the consent and the contact details before the first call, then log every contact and every stop request. Five records cover it:

If your message is marketing, also mention the right to object at first contact. For email, include a valid address for stop requests. The lead response time guide covers follow-up speed.

Typical mistakes when following up leads

Most mistakes come from assuming consent instead of checking it, or from losing a stop request.

• Treating a supplier's consent as your own. Ask for the proof before you ring the first number.
• Reusing quote details for unrelated promotions. Newsletters and offers for other products need their own consent or a valid exception.
• Adding a promotion to a booking text. The Regulations require consent for marketing information in an SMS sent for another purpose.
• Losing stop requests. Each of the DPC's three 2024 cases involved contact after the person had said they did not want it.
• Leaving it to a call centre. Give any agent the same suppression list your own staff use.

If a case does not fit any of this, ask the DPC or a solicitor before the first message goes out. Do not wait for the first complaint. For buying decisions, see where to buy solar leads in Ireland.