Consent Mode v2 and the DMA: what changed for European advertisers

Abstract orange illustration on a dark background: a padlock. Article topic: “Consent Mode v2 and the DMA: what changed for European advertisers”
In brief

The Digital Markets Act (DMA) imposes obligations on large gatekeepers, including rules on combining personal data across services. In practice, for European advertisers, this has materialised as additional consent requirements on platforms, such as Consent Mode v2 signals for users in the European Economic Area. Measuring and remarketing without these signals becomes limited.

The essentials in a definition

The DMA and Consent Mode v2 define, for European advertisers, how consent conditions data combination and use of data in ads. They rest on the Digital Markets Act, the Consent Mode documentation and GA4 configuration.

What changed

The DMA requires gatekeepers to obtain adequate consent before combining personal data across services for personalised advertising. Ad platforms began requiring advertisers to communicate the consent state of EEA users through additional signals in Consent Mode (version 2), namely about user data for ads and personalisation. Consult the official documentation for current requirements.

Without these signals, features such as remarketing and audience lists may become limited.

Implementing Consent Mode v2

Use a compatible consent-management platform and set the default state to denied for the EEA. Ensure the user’s choices (ads, ad data, personalisation, analytics) reach Google tags and GA4. Test all scenarios: accept, decline and change choice. Document the configuration and provider.

Also check other ad platforms, which may have requirements of their own.

Illustrative diagram with 4 numbered steps joined by an orange line, the last one marked as done. It represents: From regulatory requirement to correct consent signal

From regulatory requirement to correct consent signal

  1. Understand the requirement per platform
  2. Configure consent and signals
  3. Test all scenarios
  4. Measure impact and audit

Impact on measurement and remarketing

With refusal, direct measurement falls and remarketing audiences get smaller. Modelling can narrow the gap under certain conditions, but does not eliminate it. Track consent rate, observed and modelled conversions, and compare with the database. Adjust expectations and targets accordingly.

Consider strengthening lawful first-party data and context as an alternative.

Large orange quotation marks on a dark background with abstract lines of text, illustrating the quote: “Without correct consent signals, personalisation and measurement stop working as before.”
Without correct consent signals, personalisation and measurement stop working as before.

Maintaining compliance

Consent must be free, informed and easy to give and to withdraw. Avoid manipulative design patterns. Review the configuration after changes to the banner, site or tags, and follow regulatory updates. This content is informational and does not replace legal advice.

Run quarterly audits.

Decision table

ElementPractical requirementConsequence of failing
Consent signalsCommunicated to tags in the EEALimited ad features
Default stateDenied until choiceTags firing without permission
BannerClear, balanced, easy to withdrawInvalid consent
MeasurementObserved and modelledWrong interpretation of drops

Common mistakes to avoid

  • Implementing without testing. Common errors invalidate consent.
  • Manipulative banners. They remove consent’s validity.
  • Comparing periods without context. The fall in observable data looks like a loss of sales.

How to measure the result

Track consent rate, signals sent, observed and modelled conversions and audience size.

Limits and exceptions

Requirements change and vary between platforms and countries, and this content is not legal advice. Modelling is an estimate. Consult official documentation and a professional when necessary.

Illustrative example

Illustrative example: a European store updates its consent platform to communicate the required signals, tests the scenarios and tracks for two months consent rate and observed and modelled conversions. It readjusts targets and strengthens direct contact with customers who consented.

Frequently asked questions

Is Consent Mode v2 mandatory?

Platforms require the signals for certain features in the EEA; consult current requirements.

Can I keep doing remarketing?

With adequate consent and correct signals; without them it is limited.

Does modelling make up for the loss?

In part, under conditions; it does not replace real data.

Does this affect only Google?

Other platforms have requirements of their own; check each.

How do I improve consent lawfully?

With a clear, honest banner that explains the benefit, without pressure.

Summary to quote

For European advertisers, implement consent with the required signals, test all scenarios, interpret measurement with modelling and adjust expectations and targets.

Sources and recommended reading

Last editorial review: October 2026. Informational content; always confirm current conditions in the official sources before deciding.

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