Google Extends Consent Requirements to Advertisers in Switzerland

At the beginning of May, 2024, Google announced that starting from July 31, 2024, it will implement its stricter consent management requirements for serving ads in the European Economic Area (EEA), the United Kingdom, and Switzerland. Their initiative aims to enhance user privacy by regulating how publishers use cookies and personal data for ad personalization, in line with Google’s EU User Consent Policy. 

Publishers and developers using Google’s advertising services like AdSense, Ad Manager, and AdMob will need to integrate a Consent Management Platform (CMP) that is certified by Google and aligns with the Interactive Advertising Bureau's (IAB) Transparency and Consent Framework (TCF), a requirement which is in place since January 16, 2024, and which aligns with the principle of obtaining explicit user consent present across EU regulations.

The EU User Consent Policy is a key part of Google's requirements for publishers and developers. Under this policy, if you use a Google product that requires this policy, you must make clear disclosures and obtain consent from users in the European Economic Area, the UK, and as of July, 2024, in Switzerland. 

Specifically, you need to get legally valid consent for the use of cookies or other types of local storage and for the processing of personal data for ad personalization. Once you’ve obtained consent, it is very important to keep records of consents obtained and to provide clear options for users to revoke consent. In addition to this, you must clearly identify any parties who might use the personal data due to your use of Google products and ensure all information provided to users about their data usage is clear and accessible. 

Failure to comply with Google’s requirement can lead to restrictions on your use of Google products or termination of agreements.

As mentioned earlier, Google’s new policy mandates that the CMPs used by publishers must be Google-certified, ensuring they meet specific criteria related to IAB’s TCF 2.0 compliance. Publishers need to verify that their CMP can handle Google’s Additional Consent specification, which supports ads technology providers which are not registered with the TCF. To help publishers choose compliant platforms, Google will list certified CMPs. If a publisher opts not to use a Google-certified CMP, they will face restrictions such as being only able to serve limited ads. This highlights the necessity of adopting compliant CMPs to continue serving both personalized and non-personalized ads effectively.

Google has already started the process of certifying CMPs as of May 2023. Publishers using CMPs have been encouraged to engage with their providers about the certification process to ensure a seamless transition in order to meet the January 16, 2024 deadline. In the case of newer publishers or those looking to switch CMPs, these can refer to a list of Google-certified CMPs, which will be updated regularly.

The policy also extends to app publishers, who must integrate the Google User Messaging Platform (UMP) SDK to manage consent effectively within apps. Additionally, Google stipulates strict guidelines for child-directed apps, ensuring that no personalized ads are served to underage users, aligning with the Google Play Families policies.

These requirements reinforce Google’s commitment to upholding privacy standards and legal compliance across its advertising platforms. A best practice for publishers would be to prepare ahead of the deadlines to ensure their ad operations remain uninterrupted and compliant with the latest privacy regulations, especially those in Switzerland.