A marketer’s guide to Google Consent Mode v2

The enforcement of the European Digital Markets Act (DMA) from March 2024 has set the stage for significant changes in online advertising practices. In response to this regulatory shift, tech giants like Google have introduced Google Consent Mode v2, a crucial tool for advertisers targeting users in the European Economic Area (EEA). This update aims to ensure compliance with evolving online cookie tracking consent regulations under the DMA.

Google Consent Mode: The basics

Google launched Consent Mode in September 2020 in response to two laws that apply throughout the European Economic Area (EEA) (which includes every EU country plus Iceland, Liechtenstein, and Norway) and in the UK:

• The ePrivacy Directive, which requires website and app operators to get consent for most cookies and similar technologies.
• The General Data Protection Regulation (GDPR), which sets a strong, opt-in consent standard.

Most businesses operating in the EEA or UK need to get consent for advertising and analytics cookies, regardless of where those businesses are based.

Google also has obligations under a new EU law called the Digital Markets Act (DMA). The DMA regulates how Google manages the third parties using its services (like your company).

Refusing consent

When a user visits your website, your Consent Management Platform (CMP) (if you use one) will display a cookie banner or popup asking the user to consent to advertising and analytics cookies.

If the user consents, cookies will be placed on their device. These cookies may monitor how the user behaves on your website and across the web for advertising and analytics purposes.

If the user takes no action or refuses consent, no cookies will be placed on the user’s device. This means you won’t be able to monitor the user’s individual behaviour or serve them personalized ads.

However, Google Consent Mode provides some insights about the activities of users who do not consent to cookies.

Conversion modelling

If a user does not consent to advertising or analytics cookies, Google won’t write or read cookies on the user’s device. This means you lose some insights on the proportion of your users who do not consent.

But Google Consent Mode provides another way to gain insights about users known as “conversion modelling”.

Using machine learning, Google looks at historical trends and other data to draw inferences about how non-consenting users are likely to behave on your site – without identifying them individually.

As such, your Google Ads campaign reports still provide some data about ad conversions for users who have not consented.

Google Consent Mode v2: Main Changes

Google introduced Consent Mode v2 in late 2023. Here’s a summary of the main changes:

Granular Consent

Under the GDPR, consent must be “specific”. For example, a person should be able to consent to analytics cookies but not advertising cookies. This is sometimes called “granular” consent.

The original version of Consent Mode already recorded a user’s granular consent preferences via a set of parameters in the Consent Mode API. These parameters tell Google about a user’s preferences in areas such as advertising, analytics, and security.

Google Consent Mode v2 introduces two new parameters to the Google Consent Mode API:

• ad_user_data: A string that sets consent for sending data to Google for advertising purposes
• ad_personlization: A string that sets consent for personalised ads.

These new parameters are intended to help Google comply with its obligations under the DMA and help you meet the requirements of the ePrivacy Directive and GDPR.

What you need to do

Now we’ll explain what you need to do before Google’s Consent Mode v2 deadline of March 2024.

Depending on your circumstances, there are five possible routes for meeting Google’s requirements:

1. Check in with your CMP provider
2. Turn on Consent Mode in your CMP
3. Implement Consent Mode v2 manually
4. Take no action
5. Bring your website into compliance

Google appears not to have set a specific deadline date in March, so assume the deadline is 1 March 2024.

Option 1: Check in with your Cassie Account Manager or CMP provider 

Your cookie banner will automatically update to implement Consent Mode v2 before the deadline if all four of the following apply:

• You have a cookie banner
• You already use Consent Mode
• You engage in personalized advertising, and
• You use a Google-certified Consent Management Platform (CMP)

In this case, your CMP provider will do the work for you. But Google recommends you “work with your provider” to ensure everything is up to date.

Option 2: Turn on Consent Mode in your CMP 

Google recommends that you turn on Consent Mode in your CMP’s settings if all four of the following apply:

• You have a cookie banner
• You do not currently use Consent Mode
• You engage in personalized advertising, and; You use a Google-certified CMP

Turning on Consent Mode will automatically apply the v2 updates. If you don’t use Consent Mode, you won’t get the insights offered by Google’s conversion modelling features.

Option 3: Implement Consent Mode v2 manually 

You’ll need to implement Google Consent Mode v2 yourself if all four of the following apply:

• You have a cookie banner,
• You already use Consent Mode,
• You engage in personalized advertising
• You don’t use a CMP (you maintain your cookie banner yourself)

See Google’s guidance on how to manually implement Consent Mode v2

Option 4: Take no action 

You don’t need to take any action if all three of the following apply:

• You have a cookie banner
• You already use Consent Mode, and
• You don’t engage in personalized advertising

In the above circumstances, the Consent Mode v2 update is not relevant to you. If you decide to engage in personalized advertising in future, you’ll need to look at Options 1-3 above.

Option 5: Bring your website into compliance 

You should reassess your approach to cookies entirely if the following two conditions apply:

• You use Google’s products for advertising or analytics purposes in the EEA or UK, and
• You don’t have a cookie banner.

As noted above, cookie consent is an important legal requirement across Europe and in other jurisdictions. You need to find a way to request consent from your users, for example by using a CMP.

Benefits of proactive measures:

Cultivate new European audiences within Google Ads: Ensure your ads reach users who have consented to data collection, enhancing targeting accuracy.

Mitigate potential repercussions for marketing campaigns: Maintain data integrity and avoid disruptions to your marketing campaigns by proactively implementing consent measures.

Prevent data loss from non consenting users: Ensure more comprehensive analytics and insights by preventing data loss from users who don’t provide consent.

Ensure compliance with data regulations: Safeguard your business from legal issues and foster trust with your audience by adhering to data privacy regulations.

Embracing proactive measures in your digital strategy proves essential for several reasons. Firstly, these measures establish a foundation for adherence to stringent data regulations, ensuring ethical and legal compliance in your data privacy practices. Beyond regulatory considerations, being proactive serves as a preventive shield against potential disruptions in your marketing campaigns, safeguarding your brand reputation and building customer trust.

The adoption of proactive measures serves as a deterrent to data loss from non-consenting users, promoting transparency and ethical engagement with your audience. These measures unlock opportunities for expansion by enabling the cultivation of new European audiences within Google Ads.

What happens if you miss the Google Consent Mode v2 deadline?

Failing to meet Google’s March 2024 deadline for implementing Consent Mode v2 could mean that you lose access to Google’s products and insights. Google will block you from collecting any new data about EEA or the UK users in your Google Analytics audience lists, and  sharing new data about these users with Google Ads. This could mean:

• You’ll be unable to engage in remarketing with new visitors
• Google will be less effective at predicting and tracking your ad conversions
• Your ad spend could increase due to decreased efficiency
• Your campaigns could deliver worse results due to low-quality data

Cassie can help you to ensure that you are compliant within Consent Mode v2 requirements as well as global privacy legislations.

Speak to a member of our team today to address your privacy and compliance concerns and we explore how you can seamlessly meet Google Consent Mode requirements.