Mandatory Account Creation And "Guest Checkout": EDPB Recommendation No. 2/2025

The European Data Protection Board (EDPB) has opened for public consultation its Recommendation No. 2/2025, which examines the legal bases for forcing users to create accounts in order to shop on e-commerce websites.

This guidance will remain open for comments until 12 February 2026. The key points highlighted in the draft are as follows:

• Core Principle: "Guest Checkout" Should Be the Default Option:
  The EDPB states that, as a general rule, allowing users to shop without creating an account (via "Guest Checkout") is the most appropriate approach. Requiring users to create an account is considered contrary to the GDPR principles of data minimisation and data protection by default.