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ARTICLE · 14 MAY 2025

CNIL Launches Public Consultation On Draft Recommendations Relating To Multi-terminal Consent

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On April 24 2025, the French supervisory authority (CNIL) issued a draft recommendation to address challenges in collecting user consent for cookies and trackers across multiple devices (the Draft Recommendation).

European UnionPrivacy
Nigel Parker
Nigel Parker
Laurie-Anne Ancenys
Laurie-Anne Ancenys
Dalila Korchane
Dalila Korchane
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On April 24 2025, the French supervisory authority (CNIL) issued a draft recommendation to address challenges in collecting user consent for cookies and trackers across multiple devices (the Draft Recommendation). The new Draft Recommendation is subject to public consultation and, once finalised, will amend the CNIL's previous Recommendation on cookies and other trackers published in 2020 (available here, in French). The consultation is significant as the CNIL identified the collection of data via mobile applications as an enforcement priority for 2025 (see CNIL enforcement roadmap here).

The CNIL notes that a multi-terminal consent system – a "cross-device" consent solution – is optional. However, the Draft Recommendation seeks to clarify the requirements for collecting multi-device consent. For example, the Draft Recommendation defines multi-terminal consent, outlines the legal conditions for obtaining multi-terminal / cross-device consent, and provides practical

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