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EU ePrivacy Directive Deadlines and Compliance Calendar

Current-state milestones plus a recurring cadence for cookies and marketing compliance.

Focus: directive baseline, guidance milestones, and evidence freshness.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

ePrivacy compliance does not end after a banner redesign. It breaks when trackers change, consent logging drifts, or suppression lists stop propagating. Use this page to anchor on the current directive baseline and major guidance milestones, then run a repeatable cadence for tracker audits, CMP QA, consent-log verification, and direct-marketing suppression audits. This page does not modify the underlying timeline or dataflow artifacts - it gives you an operational calendar.

Section 1

Current baseline and guidance milestones

Your day-to-day obligations still come from the directive as implemented in national law, not from the proposed regulation. The most useful timeline points are therefore the current directive baseline and the major GDPR-era guidance documents.

Use these milestones to frame your documentation, training, and annual legal review checkpoints.

  • 12 July 2002, Directive 2002/58/EC entered into force as the sector-specific privacy framework for electronic communications.
  • 25 November 2009, Directive 2009/136/EC updated Article 5(3) and strengthened the consent model for storing or accessing information on terminal equipment.
  • 25 May 2018, the GDPR started applying, which made the GDPR conditions for valid consent central to many ePrivacy implementations.
  • 12 March 2019, EDPB Opinion 5/2019 clarified the ePrivacy and GDPR interplay and competence split.
  • 4 May 2020, EDPB Guidelines 05/2020 on consent reinforced the positions on valid consent and cookie walls.
  • 18 January 2023, the EDPB Cookie Banner Taskforce report summarized common enforcement positions on reject options, pre-consent firing, and withdrawal.
Recommended next step

Turn EU ePrivacy Directive Deadlines and Compliance Calendar into an operational assessment

Assessment Autopilot can take EU ePrivacy Directive Deadlines and Compliance Calendar from planning deadlines, owners, and milestones from this page to a reusable workflow inside Sorena. Teams working on EU ePrivacy Directive can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 2

Quarterly cadence - tracker governance

Most compliance failures happen through silent drift: new tags, new SDKs, new vendors, and new purposes that bypass review.

Run quarterly tracker audits the way you would run a security or release-control review.

  • Run a tracker scan, tag-manager export, network scan, and mobile SDK list diff.
  • Update the Article 5(3) decision table, consent versus exemption, and re-approve any changes.
  • Verify pre-consent blocking with automated tests and spot checks in production.
Section 4

Biannual cadence - direct-marketing suppression audit

Direct-marketing complaints often come down to suppression failures, not policy wording.

Treat suppression integrity as a control that needs recurring testing.

  • Audit suppression-list governance, access, approvals, and change logs.
  • Test vendor propagation end to end, unsubscribe to suppression to no further send.
  • Reconcile CRM and ESP segments against the suppression source of truth.
Section 5

Annual cadence - enforcement readiness rehearsal

You should be able to answer what trackers you run, why, how consent works, and what logs prove it.

Rehearse evidence exports like an incident tabletop exercise.

  • Export pack, tracker decision table, CMP snapshots, consent-log schema, and test results.
  • Marketing pack, consent model, capture logs, suppression governance, and vendor list.
  • Annual legal review, confirm national guidance updates, DPA positions, and any legislative reform movement, then document what changed and who approved it.
Primary sources

References and citations

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