Consent Mode v2 and the March 2024 deadline for EEA traffic
Google will enforce its EU user consent policy more strictly from March 2024. A checklist for consent signals, audience lists and conversion setup if you advertise to people in the EEA.
Google has told advertisers that it is strengthening enforcement of its EU user consent policy in March 2024. If you advertise to people in the European Economic Area and use remarketing, audience lists or measurement from Google tags, you will need to collect consent and pass it to Google through an updated version of Consent Mode. Three months is enough time to do this carefully, but not enough to leave it until January.
What Google is asking for
Google's EEA help page for advertisers sets out four steps. Obtain consent from end users, either directly or through a consent management platform. Set up Consent Mode to pass those choices to Google. Migrate to GA4, since Universal Analytics stopped processing data on July 1, 2023. And update to the latest APIs or SDKs.
The version update adds two parameters to the existing ad_storage and analytics_storage signals. ad_user_data controls whether user data can be sent to Google for advertising purposes, and ad_personalization controls whether ads can be personalized, which covers remarketing. Each takes the value granted or denied. Google's developer documentation says Consent Mode users need to send the two new parameters.
What stops working if you do nothing
Google says that without accurate consent signals, ad personalization and measurement features for EEA traffic degrade. Two specifics from its documentation:
- Customer Match. From March 2024, lists used in the EEA need both consent fields set to granted. Lists uploaded before March can continue to be used until they expire or are removed, but only with the Google services used before that date.
- Offline and API uploads. Audiences uploaded through APIs that have not been updated will degrade from March 2024. Manual uploaders must complete a consent attestation in the Google Ads interface, and Customer Match upload partners must complete the upgrade.
App advertisers are included. Google says to use the latest SDK or conversion tracking API so that consent signals reach it.
A checklist to work through
- Find out what you have. Which consent banner or platform runs on your site, and does it already send signals to Google? If you use a Google-certified consent management platform, ask the vendor whether it supports the two new parameters and when.
- Set defaults before tags fire. Google's documentation says to set the default consent state on every page before any config or event commands, and shows how to scope defaults by region using ISO codes, so you can apply stricter defaults to the EEA than elsewhere. If your banner loads asynchronously, the wait_for_update setting gives it time to send the user's choice before tags run.
- Send updates when the user chooses. The updated state must be sent when someone accepts or rejects, and applied on later pages. Test both paths.
- Check Tag Manager. If you deploy through Tag Manager, use a consent mode template or the consent APIs, and confirm tags that serve ads require the right consent types.
- Update your uploads. Check which API version your Customer Match and offline conversion uploads use, and what consent value you send for each user. Ask any partners who upload for you the same question.
- Update apps. Make sure your measurement partner and Google SDKs are current in your next release.
Basic or advanced mode
You will see two implementation styles described. In the basic style, tags stay blocked until consent is granted, and nothing is collected beforehand. In the advanced style, Google tags load first and send cookieless pings when consent is denied, and Google can use those to model conversions. That description comes from a consent platform vendor, which has a commercial interest in recommending the more involved option. Choose based on your legal advice and your appetite for modeled data, not on a vendor's preference.
Expect your reported numbers to change
Where users decline consent, Google will see less. That is a legal and ethical choice and not something to engineer around. Plan for smaller remarketing audiences in the EEA, and treat modeled conversions as an estimate. Compare reported EEA conversions with your backend totals before and after the change, and keep a note of the date you switched.
Also remember that Consent Mode only tells Google's tags what the user chose. It does not make a banner compliant by itself, and the banner and its wording remain your responsibility. If you have doubts, ask your privacy counsel.
The takeaway: audit your banner, defaults, tags and list uploads now, fix them in December, and leave January for testing.