According to the RFCs, does an email require a TO: address or is it ok
to just have BCC: addresses?
That's strictly an issue of what is in the headers (the actual mail transport doesn't distinguish between To:, Cc: and Bcc: addresses).

Technically, RFC822 requires at least one To: header, or at least one Bcc: header (which can (and obviously should) be blank).

-Scott
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