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ARTICLE · 01 MAY 2026

ICO Cookie Crackdown 2.0: The ICO’s New Storage And Access Technologies Guidance

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The UK Information Commissioner's Office has finalized its guidance on storage and access technologies, expanding compliance requirements beyond traditional cookies to include tracking pixels, device fingerprinting, and web storage. Organizations must now navigate stricter consent standards and three new narrow exceptions introduced by the Data (Use and Access) Act 2025, while facing significantly increased enforcement penalties of up to £17.5 million or 4% of annual worldwide turnover.

United KingdomPrivacy
Kady Hammer
Kady Hammer
Zach Judge-Raza
Zach Judge-Raza
Melissa Maalouf
Melissa Maalouf

In a previous blog, we discussed the UK Information Commissioner’s Office (“ICO”) prioritizing online advertising and cookie banner compliance. Following consultations last Autumn, the ICO finalized its Guidance on the Use of Storage and Access Technologies in April 2026 and updated its Online Tracking Strategy. The ICO has held firm on its enforcement position: organizations must give users meaningful, informed, and easy choices about online tracking, and compliance expectations now extend beyond traditional cookies.

Expanded Scope: Not Just Cookies

The most important shift is definitional. The ICO’s April 2026 guidance emphasizes that the Privacy and Electronic Communications Regulations (“PECR”) applies not only to cookies, but also to a broader category of storage and access technologies (“SATs”), including:

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