Google Consent Mode checklist to meet Google’s EU privacy requirements

Our Google Consent Mode (GCM) checklist helps you understand and comply with Google’s requirements. Obtain and signal valid user consent for privacy compliance. Safeguard your marketing and advertising operations.
Resources / Checklists / Google Consent Mode checklist to meet Google’s EU privacy requirements
Published by Usercentrics
6 mins to read
Mar 25, 2024

As of March 2024, Google has new requirements for compliance with European data privacy regulations and enforcement of their EU user consent policy. These requirements apply to third-party companies using Google services for online advertising.

This checklist outlines requirements that Google has put in place to meet requirements of European data privacy regulations and enforcement of their EU user consent policy. It also covers how companies can meet these requirements. Google’s requirements apply to third-party companies using Google services for online advertising, with an implementation deadline of March 2024.

Google Consent Mode (GCM) is a solution that interacts with your CMP’s consent banner. When user consent is obtained via the banner, GCM signals the consent information to Google services, enabling tags to adjust their behavior to respect user choice, e.g. for personalized advertising.

As of March 2024, Google is requiring companies using Google advertising services like Google Ads, Google Analytics, and/or the Google Marketing Platform in the EU/EEA and UK to use Google Consent Mode v2 (the latest version) with a Google-certified consent management platform (CMP), like Usercentrics CMP.

Companies must signal valid user consent to Google via Consent Mode in order to use personalization features to serve ads.

Learn more in our Google Consent Mode Resource Hub.

With the latest version of Consent Mode (v2), Google has introduced two new parameters. This enables signaling of consent information for personalized advertising.

Usercentrics CMP has Google Consent Mode integrated and activated by default, so when users’ consent choices are received, they are sent to Google to control tags or SDKs and adjust their behavior to meet data privacy requirements.

Google Consent Mode also enables privacy-compliant modeling to recover lost conversions when users do not provide consent.

Currently Consent Mode supports the following Google services:

  • Google Analytics
  • Google Ads (Google Ads Conversion Tracking and Remarketing)
  • Floodlight
  • Conversion Linker

Google introduced its EU user consent policy in 2015. It’s been updated several times to meet evolving regulatory requirements, like those from the GDPR, ePrivacy Directive, and Digital Markets Act (DMA).

Google announced in early 2024 that they would be increasing enforcement of the EU user consent policy. This is to enable the company to comply with data privacy regulations, including DMA enforcement.

Read on to learn about:

  • requirements for legally valid consent
  • how Google Consent Mode works
  • which Google services the requirements apply to
  • How to set up a CMP with Consent Mode to meet Google’s requirements
  • and more! 

Important information

When is Google’s deadline?

Google has not publicized a specific date but has said that they will begin enforcement by March 2024.

What regions are included in the requirements?

Users online in the European Union, European Economic Area, and/or United Kingdom, to whom companies target advertising.

The policy is based on requirements of regulations like the General Data Protection Regulation.

It’s main requirements for third parties using Google services:

  • legally valid consent must be obtained from end users for:
    • use of cookies or other local storage where legally required
      and
    • collection, sharing and use of personal data for ad personalization
  • when requesting end user consent, parties must:
    • retain records of users’ consent
    • enable end users to revoke consent at any time and provide clear instructions to do so

What Google services are included in the requirements?

The requirements apply to companies using Google’s advertising platforms or services, like Google Ads, Google Analytics, or Google Marketing Platform.

Specifically, if companies are using the personalization functions of those services, they must be able to prove that they have obtained users’ prior consent.

Did you know?
Usercentrics CMP was one of the first certified by Google for these new requirements.

Google is requiring companies that run personalized advertising to implement a certified consent management platform (CMP) to obtain prior consent from users for collection of their personal data for advertising purposes.

The CMP implemented must integrate with the latest version of Google Consent Mode (v2 is the first with the signaling functionality).

Usercentrics CMP has Google Consent Mode integrated and activated by default when its’ installed.

The original version of Consent Mode (launched in 2020) helped to enable data tracking and insights, even when users did not provide consent.

Google Consent Mode v2 released in November 2023 and included two new settings:

  • ad_user_data
  • ad_personalization

These settings control personal data usage and ad personalization based on user consent, and enable signaling valid consent obtained via a CMP to Google’s services.

Currently Consent Mode supports the following Google services:

  • Google Analytics
  • Google Ads (Google Ads Conversion Tracking and Remarketing)
  • Floodlight
  • Conversion Linker

Important: Usercentrics CMP’s automated scan detects all the data processing services you’re using, saving time and resources in categorizing them, and helping to ensure users get compliant notifications and informed options.

Start with one of Usercentrics CMP’s user-friendly templates, or fully customize your banner design and contents. Make sure you know which regulations apply to your business, and set up the CMP accordingly.

For example, ensure granular information and consent options are available about all the data processing services you use (cookies and other tracking technologies), and/or request prior consent from users in the EU and elsewhere that laws require it.

The Usercentrics CMP consent banner enables users on websites and apps to record their consent preference for use of their personal data with the click of a button. They can also revoke consent or update their preferences at any time. The consent information is signaled to Google, and is also securely stored in the event of an audit or data subject access request.

1. Configure Usercentrics Web or App CMP

Scan all Data Processing Services and SDKs in use on your website or app. Quickly set up and fully customize Usercentrics CMP to meet the requirements of the legal framework you want to comply with via our intuitive user interface.

2. Implement the CMP on your website or app

Add the CMP script tag to your website or Google Tag Manager. Adjust the Data Processing Services scripts found by the scan. For apps, there’s easy implementation with the Usercentrics App CMP SDK.

Google Consent Mode v2 is active by default so you’re ready to collect and signal valid user consent.

3. Enjoy the benefits of Consent Mode v2

Respect users’ consent choices while automatically adjusting Google tags and SDK behavior by passing the consent signal to Google. Collect additional user insights with conversion modeling and Advanced Consent Mode, even when users don’t give consent.

Important: Use of consented data and conversion modeling may impact the performance reported in Google Ads. However, these models aim to minimize over-prediction, ensuring that ad spend is optimized based on the most accurate data available.

Basic Consent Mode

With the basic Consent Mode implementation, it prevents Google tags from loading until a user interacts with a consent banner.

The user would have to provide their consent via the consent banner, which is displayed by Usercentrics CMP. Then Google Consent Mode in the CMP integration would signal consent to Google to control the tags.

This setup does not transmit any data to Google prior to user interaction with the consent banner.

Advanced Consent Mode

With the advanced Consent Mode implementation, Google tags send cookieless pings when users decline consent.

This enables Google to provide modeled data for Google Analytics 4 properties, which helps in retaining insights for optimization.

Combining advanced Consent Mode with Usercentrics CMP’s Analytics Dashboard and A/B Testing feature enables even more insights to optimize user consent for data collection.