Tracking Pixels In Emails: The Garante’s New Guidelines And Requirements For Businesses

By means of Provision No. 284 of April 17, 2026, the Italian Data Protection Authority (the “Garante”) has adopted guidelines on the use of so-called “tracking pixels” in email communications, intended for all entities, both public and private, that use such tracking tools for any purpose. The provision, currently being published in the Official Gazette, grants recipients a six-month period to comply with the new requirements.  

What are tracking pixels and why has the Garante intervened?

Tracking pixels are transparent images of an extremely small size, just one pixel, which are not directly contained within the email but hosted on remote servers. When the message is opened, an HTML code embedded in the email automatically triggers a request to the sender’s server, allowing the sender to obtain information on whether the message has been opened, the recipient’s IP address, the type of device used, the time of access, and the number of subsequent openings.