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How to Implement Google Consent Mode V2 with Digital Markets Act Compliance

Navigating the evolving landscape of data privacy regulations and user consent can be a daunting task for website owners. With the introduction of Google Consent Mode v2, a powerful tool emerges to streamline this process while aligning with stringent guidelines such as the GDPR and the Digital Markets Act (DMA).

This update not only enhances compliance but also empowers users by facilitating transparency and control over their data collection preferences.

Google Consent Mode v2 is a comprehensive solution that enables websites to efficiently communicate users’ cookie consent preferences to Google tags, governing personalized advertising, conversion tracking, and data modelling.

By implementing this tool, businesses can navigate the complexities of privacy regulations across regions like the European Economic Area (EEA) while leveraging Google’s insights and data capabilities.

Seamless integration with Consent Management Platforms (CMPs) further simplifies the process, ensuring a seamless user experience and adherence to the evolving digital privacy landscape, helping you keep an excellent UX and positively affecting your SEO.

Understanding the Digital Markets Act (DMA)

Overview of DMA

The Digital Markets Act (DMA) is a set of rules created by the European Union to ensure fair competition in digital markets, particularly among large tech companies known as “gatekeepers.” These gatekeepers are defined as large online platforms with a strong economic position, significant market impact across multiple EU countries, and a durable intermediation position linking a large user base to numerous businesses.

On September 6, 2023, the European Commission designated six companies as gatekeepers: Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft, encompassing a total of 22 core platform services provided by these entities.

Navigating the evolving landscape of data privacy regulations and user consent can be a daunting task for website owners.
Navigating the evolving landscape of data privacy regulations and user consent can be a daunting task for website owners.

Implications for Digital Advertisers

The DMA aims to create a more level playing field by preventing gatekeepers from using unfair practices that disadvantage competitors and consumers. This could potentially open up new opportunities for ad placements and partnerships. And also democratize access to user data traditionally guarded by the gatekeepers. That would lead to more innovative and targeted advertising strategies.

However, the DMA also introduces increased transparency requirements for digital advertisers. They will need to disclose how they collect and utilize user data for targeted advertising, communication between services, and potentially reevaluate their business models. Advertisers operating in the EU and European Economic Area (EEA) will need to reassess their operations across various tech companies. They will have to consider how they advertise and run their businesses as a whole.

Key Compliance Requirements

The DMA establishes a set of “do’s” and “don’ts” that gatekeepers must comply with in their daily operations. Some key requirements include:

  • Allowing third-party interoperability with the gatekeeper’s services in certain situations.
  • Providing advertisers and publishers with tools and information necessary for independent ad verification.
  • Allowing business users to promote their offerings and conclude contracts with customers outside the gatekeeper’s platform.
  • Prohibiting preferential treatment of the gatekeeper’s own services or products over third-party offerings.
  • Preventing the tracking of end-users outside the gatekeeper’s core platform service for targeted advertising without explicit consent.


Failure to comply with the DMA can result in
fines of up to 10% of the company’s total worldwide annual turnover, or up to 20% for repeated infringements. In cases of systematic infringements, additional remedies, including behavioral and structural remedies such as divestiture of business units, may be imposed.

What is Google Analytics Consent Mode V2

Google Consent Mode V2 is an enhancement of the original Google Consent Mode, designed to better align with data privacy regulations and user preferences. This tool allows websites to efficiently communicate users’ cookie consent preferences to Google tags.

Google Consent Mode V2 is an enhancement of the original Google Consent Mode, designed to better align with data privacy regulations and user preferences.
Google Consent Mode V2 is an enhancement of the original Google Consent Mode, designed to better align with data privacy regulations and user preferences. Image source: https://www.iubenda.com/en/help/27137-google-consent-mode

Overview of Consent Mode V2

Google Consent Mode has become an important tool for adapting the collection of data on websites to individual user decisions. With the latest update to version 2, Google Consent Mode is expanding its functions and presenting companies with new decisions. Google Consent Mode is a framework that makes it possible to control the functioning of Google services. Such examples are Google Ads and Google Analytics 4 on websites based on the user’s consent.

New Parameters Added in V2

Google Consent Mode V2 introduces new parameters including ad_user_data and ad_personalization, in addition to the existing analytics_storage and ad_storage. In version 2 of Google Consent Mode, two additional parameters have been added to the existing parameters. The first is ad_user_data for the use of personal data for advertising purposes. The second is ad_personalization for the use of data for remarketing purposes.

The current Consent Mode parameter tags (analytics_storage and ad_storage) were related to data collection only, while these two new Consent Mode v2 tags (ad_user_data and ad_personalization) relate to how data is used and shared. These parameters offer enhanced control over user data and advertising personalization based on user consent.

Differences Between Basic and Advanced Modes

There are two implementation options for Google Consent Mode V2: Basic and Advanced. Google Consent Mode can be implemented in two variants: Basic and Advanced. It is crucial to consult with your own data protection department.

  1. Basic Consent Mode:
    • Here, all signals/parameters are set to “Denied” by default, which means that no data is collected without the user’s consent.
    • Basic implementation involves full data collection with user consent and no data collection without it.
    • The Basic consent mode enables conversion modeling in both Google Ads and Google Analytics to extrapolate the behavior of unconsented users, but it blocks behavioral modeling in Google Analytics.
  2. Advanced Consent Mode:
    • Here, user consent is not required to send data to Google services. “Anonymized” network requests are sent to Google servers, even if there is no consent.
    • It is important to note that these “anonymized” pings still collect the user’s IP address, which Google only uses for localization purposes and then claims to discard.
    • Advanced implementation allows limited, anonymous data collection without consent for modeling purposes, while respecting user privacy.
    • The Advanced Consent Mode allows us to use both behavioral modeling and conversion modeling. Advanced modeling is used to extrapolate the behavior of unconsented users for Google Ads and Google Analytics, and behavioral modelling is used for Google Analytics.


Companies must clarify with their data protection department. They should know whether the existing consent categories in their CMP are sufficient for a data protection-compliant implementation. A decision must be made as to which variant of Google Consent Mode v2 will be implemented. And also whether a new consent category is required.

Steps to Implement Consent Mode V2 with Google Analytics 4

Prerequisites and Initial Setup

Before you begin implementing Google Consent Mode V2, ensure that your website or app meets the following prerequisites:

  1. Set the default consent state to ‘denied’ for all consent types. This ensures that no data is collected without the user’s explicit consent.
  2. Update the consent state based on the user’s interaction with your consent settings. As soon as a user interacts with your consent management solution, update the consent status accordingly.
  3. Scope the default consent settings to the regions where you are surfacing consent banners. This helps preserve measurement in regions where consent banners are required and Google tags adjust their behavior accordingly.
  4. Load the Google tag (default snippet code) first, followed by your consent solution. If your consent solution loads asynchronously, ensure the correct order by following the guidelines for integrating with asynchronous consent management platforms.
  5. If not handled by your consent solution, call gtag(‘consent’, ‘update’, …) after the user indicates consent.

Configuring Google Tag Manager

Follow these steps to configure Google Consent Mode V2 in Google Tag Manager:

  1. Enable Consent Preview (BETA): In the GTM Admin interface, navigate to Container Settings and tick the “Enable consent preview (BETA)” box under Additional Settings. Click “Save.”
  2. Review Tag Permissions: Examine all tags and their permissions.
  3. Require Additional Consent: Go to the workspace, click on “Tags,” and then the shield button. Select all required tags and click the shield with a cog icon. Check the “Require additional consent for tag to fire” box and add the required consent variables (ad_storage, analytics_storage, ad_user_data, and ad_personalization). Click “Save.”

Direct Implementation Guidelines

If you’re not using Google Tag Manager, follow these guidelines for direct implementation:

  1. Set Default Consent State: Call the gtag(‘consent’, ‘default’, …) command on every page before any commands that send measurement data.
  2. Update Consent State: Use the gtag(‘consent’, ‘update’, …) command to send the user’s consent status. Update the consent status as soon as the user interacts with your consent management solution.
  3. Maintain Code Order: Ensure the code runs in the correct order: load the Google tag, load your consent solution, and then call gtag(‘consent’, ‘update’, …) after the user indicates consent.
  4. Send Consent Parameters: In addition to ad_storage and analytics_storage, send the new parameters ad_user_data and ad_personalization with their respective ‘granted’ or ‘denied’ values.
  5. Specify Regions (Optional): To fine-tune defaults based on user locations, specify a region in your consent command.
  6. Enable URL Passthrough (Optional): Set the url_passthrough parameter to true to store ad information in first-party cookies for improved event accuracy.
  7. Redact Ads Data (Optional): Set ads_data_redaction to true to further redact your ads data when ad_storage is denied.

By following these steps, you can ensure that your website or app is compliant with data privacy regulations and respects user consent preferences when implementing Google Consent Mode V2 with Google Analytics 4.



One way of implementing the Consent Mode V2 is with Google Tag Manager.
One way of implementing the Consent Mode V2 is with Google Tag Manager.

Troubleshooting Common Issues in Consent Mode V2

Common Implementation Errors

You may encounter several common errors during the implementation of Google Consent Mode V2. One such error is “A tag read consent state before default was set”. This error occurs when the default consent state has not been defined or properly configured during the setup of the CMP Tag in Google Tag Manager (GTM). It can also happen if you’ve used the Custom Script method to implement GCM and the custom script is missing from your website.

Another potential issue is the “Consent not updating” error. This error occurs when the consent preferences of users are not properly updated or recorded. To resolve this, ensure that you have enabled “Support GCM” from the CMP dashboard and submitted and published the changes. Additionally, verify that the CMP tag is fired first, before any other tags on the website, and update the CMP tag script to the latest version (Consent Mode v2).

The “Tag firing before consent initialization” error occurs when other tags are read or fired before the default consent is set. To fix this, ensure that the trigger “Consent Initialization – All pages” is set only for the CMP Tag, allowing it to fire first before any other tags. Verify that all directly loaded tags are fired only after GTM is completely loaded by using the Tag Assistant debug console.

Debugging with Google Tag Assistant

Google Tag Assistant is a powerful tool that can help you verify and troubleshoot your consent mode implementation on your website. With Tag Assistant, you can check:

  • Whether your website sets the correct default consent state before any tags fire.
  • Whether your website updates consent states correctly after visitors grant or deny consent.
  • Which tags check for which consent types.
  • Whether the required consent types were granted when each tag triggered, and whether the tag passed the checks for any additional required consent.


To verify your consent setup using Tag Assistant, follow these steps:

  1. Open Google Tag Assistant and enter your website’s URL.
  2. On your website, open the cookie banner and accept all.
  3. In Tag Assistant, verify if the page set the default consent correctly by checking the “API Call” section or the “Consent” tab in the “Output” of your tag section.
  4. Verify if the page updated the consent based on your consent banner interaction by checking the most recent “Consent” event in the “API Call” section or the “Consent” tab.
  5. Check which tags fired or were blocked by the consent state by selecting the “Tags” tab and clicking on individual tags.

Best Practices for Smooth Implementation

To ensure a smooth implementation of Google Consent Mode V2, follow these best practices:

  • Set the default consent state for all consent mode parameters (ad_storage, analytics_storage, ad_user_data, and ad_personalization) to ‘denied’ before any tags fire. This ensures no data is collected without explicit consent.
  • Move all code that calls gtag(‘consent’, ‘default’, …) commands higher in the page, above any tag snippets or other code that might be using consent.
  • Use the gtag.js update command to update the consent state after a visitor interacts with your consent banner. Ensure you have an update mechanism for every parameter you set a consent default for.
  • If using a Consent Management Platform (CMP) tag template in GTM, check the CMP documentation for setting default consent and updating consent states.
  • Verify consent mode works for different user regions by setting your visitor location and checking if consent mode adapts accordingly.


By following these guidelines and leveraging tools like Google Tag Assistant, you can effectively troubleshoot and resolve common issues that may arise during the implementation of Google Consent Mode V2, ensuring compliance with data privacy regulations and respecting user consent preferences.

Conclusion

Navigating the complexities of data privacy regulations and user consent can be a daunting task, but implementing Google Consent Mode v2 with Digital Markets Act compliance can streamline the process. By adhering to the guidelines outlined in this article, businesses can ensure transparency, empower users with control over their data collection preferences, and leverage the insights and capabilities of Google’s advertising and analytics tools.

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Staying compliant with evolving regulations is crucial in today’s digital landscape. While challenges may arise during implementation, resources like Google Tag Assistant and following best practices can help overcome common issues. Embracing these changes not only ensures regulatory compliance but also fosters trust and enhances the user experience, ultimately benefiting both businesses and consumers alike.

FAQs

What is Google Consent Mode v2 and is it compliant?
Google Consent Mode v2 is a major update designed to enhance user privacy and data compliance. It provides an interface that informs Google about the consent given by a website user for cookie usage. Google Consent Mode v2 activates only when a user declines cookie usage. If consent is given, Google continues to use its cookies for tracking purposes as it normally would.

How can I set up Google Consent Mode v2 on my website?
To set up Google Consent Mode v2, follow these steps:

  • Install CookieScript CMP (Consent Management Provider) on your website.
  • Implement Google Consent Mode v2.
  • Configure your cookie banner settings.
  • Enable Google Consent Mode v2 within your banner settings.
  • Choose between Basic or Advanced Google Consent Mode according to your needs.


What are the steps to implement Google Consent Mode?

To implement Google Consent Mode, you should:

  • Load the Google tag, which is your default snippet code.
  • Load your consent solution.
  • If your consent solution does not handle it, manually call gtag(‘consent’, ‘update’, …) after the user has indicated their consent.


Does Google Consent Mode ensure GDPR compliance?
While Google Consent Mode helps with adherence to GDPR regulations, it does not automatically ensure compliance. It is essential for each business to evaluate its specific practices to ensure they are in line with GDPR requirements.

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