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Cookie Control, Google and their Consent Management Platform (CMP) requirements for serving ads in the EEA and UK

20 November 2023

Earlier this year, on May 16th, Google announced changes to their ad network which introduced requirements for all businesses using their publisher products - Google AdSense, Ad Manager, or AdMob - to use a Google-certified CMP when serving ads to users in the European Economic Area (EEA) and/or the UK.

  • You can see the changes Google made on their ad network here.
  • A Consent Management Platform (CMP) is one aspect of the Transparency & Consent Framework (TCF) responsible for informing users and capturing their preferences with respect to the processing of their personal data.
  • Google views the decision to require adoption of the IAB TCF as a continuation of its commitment to supporting industry standardisation aimed at promoting user transparency. This follows IAB Europe's finalisation of TCF v2.2, which comes into force on November 20th, 2023.

What does this mean for Cookie Control users?

  • The good news is that Cookie Control has been a certified CMP with IAB Europe since 2019 and has recently gained Google certification since adding support for Google’s Additional Consent Specification in Cookie Control v9.9.2.
  • This version extends the latest TCF v2.2 specification by adding support for companies that are not yet registered vendors on IAB Europe's Global Vendor List (GVL) but are included on Google's Ad Tech Providers (ATP) list.

How to run Cookie Control as a Google certified CMP?

  • To run Cookie Control as a Google Certified CMP, a Pro, Multi Site, or Enterprise licence is required. Your configuration must also include the iabCMP property as shown below.
  • const config = {
      apiKey: 'xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx',
      product: 'XXX',
      iabCMP: true
    }
  • This will render Cookie Control as an IAB registered Consent Management Provider (CMP)and in turn present IAB Europe's standard purposes, features, vendors, and legal descriptions to users so that they may signal their consent at various levels of granularity.
  • The onus is then on IAB registered vendors and Google's ATP list to test the relevant consent state recorded (encoded as a TC String in accordance to the TCF v2.2 specification) and behave accordingly.
  • No further set up is required, though Cookie Control does supports the CMP API v2.2 as outlined by TCF v2.2 should you wish add any additional behaviour.
  • For more information, please see the IAB TCF v2.2 section of our documentation.

What if only Google Analytics is required?

  • If your site only needs to support Google Analytics 4, then Google consent mode is still the recommended way of set up. This article explains how to integrate Google Consent Mode with Cookie Control and is available for all licence tiers.
  • In some cases, Google Tag Manager (GTM) may attempt to fire tags before Cookie Control has finished loading and can provide an accurate consent status.
  • To handle this, Google recommends adding the wait_for_update when setting your default consent statuses to better support the asynchronous nature by which Cookie Control loads.

More info

For more information, please refer to Google's documentation