FAQEU

EU ePrivacy Directive CMP Consent Logs

CMP consent logs should prove what the user was asked, what choice they made, which cookies or vendors that choice covered, and whether refusal or withdrawal was honored.

Use the log as supporting evidence for Article 5(3) storage or access and GDPR-standard consent, not as a substitute for a lawful banner, accurate cookie inventory, or Member State legal review.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
8

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

For EU ePrivacy cookie and tracker consent, a should retain enough information to replay the consent moment without collecting unnecessary extra tracking data. The useful record links the user's choice to the banner text, purposes, vendors, cookie inventory, and withdrawal path that existed when storage or access to terminal equipment occurred.

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4 of 4 questions
Question 2

Which validity signals should the log preserve?

A log is useful only if it captures consent quality, not just a positive flag. Preserve signals showing that the user saw clear purpose information, made a granular affirmative choice, could refuse optional cookies or trackers, and could later withdraw without undue effort.

For review, keep the evidence that the CMP did not rely on silence, pre-ticked boxes, scrolling, inactivity, or a design that made acceptance look mandatory. If the banner changed, keep the old versioned proof because later screenshots do not prove what a user saw earlier.

  • Consent was recorded by a clear affirmative action for named purposes rather than by inactivity or a preselected default.
  • Purpose-level and vendor-level choices match the CMP configuration and the cookie or tracker inventory active at the timestamp.
  • Reject, continue-without-consenting, or equivalent refusal handling was available where the banner requested consent.
  • Withdrawal was available through a visible, accessible route and was not materially harder than the original consent action.
  • The CMP blocked or suppressed optional tags, pixels, SDK calls, and storage until the relevant consent state allowed them.
Citations
CJEU Planet49 judgment

Supports treating pre-ticked cookie consent as insufficient and preserving the information provided to users for cookie consent.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Supports treating pre-ticked cookie consent as insufficient and preserving the information provided to users for cookie consent.
"pre-ticked checkbox"
eur-lex.europa.eu
Referenced sections
  • Grounds the need to connect CMP records to storage of, or access to, information in user terminal equipment.
"storing of information"
edpb.europa.eu
Referenced sections
  • Supports the caveat that taskforce positions are a minimum threshold and do not replace case-by-case authority analysis or national requirements.
"minimum threshold"
edpb.europa.eu
Referenced sections
  • Grounds the validity checks for freely given, specific, informed, unambiguous consent and easy withdrawal.
"freely given, specific, informed and unambiguous"
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