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French CNIL Provides Guidance on Cross-Device Cookie Consent - JD Supra

CNIL (France) January 29, 2026 medium impact

French CNIL Issues New Guidance on Cross-Device Cookie Consent Requirements The French data protection authority (CNIL) has released updated guidance addressing cookie consent requirements across multiple devices. The guidance clarifies how organizations must obtain and manage user consent when tracking individuals across different devices and platforms. This development impacts how companies implement consent management and cookie policies in France and potentially across the EU. The CNIL's clarification addresses the complexity of modern digital ecosystems where users interact with services through smartphones, tablets, desktops, and other connected devices, requiring organizations to ensure proper consent mechanisms are in place for each device interaction.

Key Takeaways

  • arrow_right_alt CNIL provides clarification on obtaining valid consent for cross-device tracking and cookie usage
  • arrow_right_alt Organizations must implement robust consent management systems that account for multiple device interactions
  • arrow_right_alt The guidance impacts compliance strategies for companies operating in France and the broader EU
  • arrow_right_alt Cross-device tracking requires explicit user consent rather than relying on previous device consent