CNIL Requests Public Comments On Draft Recommendations On The Use Of Tracking Pixels In Emails

On June 12 2025, the French supervisory authority (CNIL) requested public comments on the draft recommendations on the use of tracking pixels in emails (Draft Recommendations).

Tracking pixels are an alternative tracking method to cookies, taking the form of a nearly invisible image embedded in an email or on a webpage. They let the sender know that a user has read the email or visited the page. The Draft Recommendations focus on the use of these pixels in emails, highlighting the growing number of complaints the CNIL has received in this area.

The Draft Recommendations note that the use of tracking pixels must comply with the provisions of the GDPR and the relevant provisions of the French Data Protection Act No 78-17 of January 6 1978 (the French Data Protection Act), with the sender of the email being considered the controller, even when subcontracting the management of the trackers to third parties. The email service providers which offer the integration of