Implementing Consent Mode v2 – Neither if nor why, JFDI

Implementing Consent Mode v2 – Neither if nor why, JFDI

Maybe I am in the wrong here, but truthfully, I wasn’t a massive objector when it came to cookies.  They were and are still transparent, relatively simple for users to manage and with a few restrictions placed on browser manufacturers, easier to police.  And yes…. I do see the other side of the argument and I do support and appreciate why legislation like GDPR and the DMA have come into being.  A cookie-less world that makes us all more secure online is a good thing.  It does feel like things have, however, become more opaque for people, not less.

Still, with that axe ground, I shall get to the point.

It’s March 1st (pinch, punch, first of the month and all that) and that means that this is the month in which website owners have to implement something that many haven’t heard of.  Google’s Consent Mode v2 becomes a mandatory implementation for site owners this month.  So, let’s take a couple of minute to look at what Consent Mode is, where it’s come from, what it effects and what you need to do.

What is Consent Mode?

Consent Mode has been around in a background, sort of hygiene way for a while and lots of Google Tag Manager (GTM) users will have seen it, but a lot won’t.  It was tucked away in the advanced features of some tags and unless you were prepared to click through a few options and do some rather uninformative reading in the Big G’s help documentation, it was hard to see the point.

Things however, changed in November last year.  That is when the EU enacted the Digital Markets Act (DMA) and Google and others were designated as “Gatekeepers” of private user data and therefore required they get explicit consent from users in the EEA for their data to be transferred and used in tools like Google Ads or Google Analytics.  Google updated the already existing Consent Mode in response, creating Version 2 in the same month and it was designated as a mandatory implementation from 1st March 2024.  In case you’ve missed it, that’s today.

If you are responsible for a website that has a user base that is in the EEA, then it is essential you upgrade to Consent Mode V2 to maintain the quality of your measurement data and audiences.

If you don’t implement CMv2, no new data about users will be captured by things like your Google Ads remarketing campaigns or GA4 – and if you’re reliant on those tools for conversions and insight, you’re going to see a massive impact.

“Ah, but we have a cookie notice on our website!  We’re golden” I hear you say.  Fair, but that is not necessarily enough.  Consent Mode moves your users into a space where they are giving explicit consent for different elements of data.  It’s designed to allow them to say yes to analytics and no to remarketing, rather than allowing site owners and advertisers to get away with the ‘Yes to all’ approach that many have been using for a long time.

How Consent Mode works

Consent Mode is powered through the cookie banner on your website.  When a user consents to cookies, their choice is passed to Google via Consent Mode and the normal data is collected.  Similarly, if a user rejects cookies, these signals are sent back to the Big G and what is collected is reduced. The smart bit though, is that Google will apply its magical machine learning tools to those users and model their conversions so some data is passed back to site owners.

All very clever.

It means however, that a functional cookie banner on your website is essential.

For this to work and for your website not to lose data, you must have in place a cookie banner that will support consent mode.

What do you need to do?

There are two levels of Consent Mode implementation.  Helpfully, they’re called Basic and Advanced.

For many site owners, Basic looks like it’s good enough because it is pretty much what they have already and are used to.  There will be sites with more complex setups that require the Advanced option so we will take a look at both.

Basic Consent Mode v2 Implementation

With the basic implementation if a user consents to cookies, the website behaves normally, firing all tags and collecting full data. For users who do not consent, no data is collected, and cookieless pings are not sent.  That isn’t far removed from how cookie banners function at the moment.

To implement Basic Consent Mode, website owners need to:

  • Set up a Consent Management Platform (CMP – “Cookie Bar”) to manage user consents.
  • Configure their website so that, when a user rejects cookies, Google Analytics 4 (GA4) tags or similar tags are not fired.
  • Integrate a consent flag to communicate the user’s consent decision to Google.

Advanced Consent Mode V2 implementation

More of the Nando’s hot and spicy implementation, compared to Basic’s lemon and herb, Advanced gives a more targeted approach. Even when users do not consent to cookies, it allows the sending of anonymous, data to Google for modelling purposes. This enables websites to recover some level of data for Google Ads and GA4, even without user consent.

An Advanced Consent Mode implementation requires:

  • Using a CMP (“Cookie Bar”) for user consent management.
  • Configuring the website so that GA4 cookies are not set when consent is denied, but a consent flag is passed to Google.
  • Sending cookieless pings to Google for data modelling.

Oh and if you’re one of those people who thinks that because you’re doing server-side tracking this doesn’t apply to you.  You’re wrong.  Consent Mode v2 requires you to respect the user at both server and client side, so you are going to have to dive into GTM and configure Consent Mode there as part of your server side tracking.

Advanced mode does mean that you’re collecting some data without the user’s consent.  It’s probably a good idea to check with those great people in legal on this before you implement the advanced mode.

What to do next?

It sounds simple, but if you’ve not so much as heard of, never mind started your Consent Mode v2 Implementation, then you need to get on it now.  Speak to your developers, your PPC partner and anyone else involved and get on this today.

There’s a reasonably helpful Google article on the implementation here: https://support.google.com/google-ads/answer/10000067?sjid=4886327721580551665-EU

If you have a consent banner and use consent mode:

If you already use consent mode and do not currently and will never engage in personalised advertising, such as remarketing, you don’t need to take any action.

If you currently use consent mode and need to engage in personalised advertising: If you use a Google-certified consent management platform (CMP), your CMP provider will automatically update to the newest version of consent mode. Please work with your provider to ensure you are using the latest consent mode update.If you maintain your own banner, implement consent mode v2.

If you have a consent banner and do not use consent mode:

If you load the Google tag and haven’t implemented consent mode, implement consent mode to use the full range of Google’s advertising capabilities:

If you use a Google-certified consent management platform (CMP), simply enable consent mode in your banner settings.

If you prevent your Google tags from loading until a user interacts with your consent banner, Google will not be able to verify user consent choices and this may lead to loss in data.

If you don’t have a consent banner and do not use consent mode:

Set up a consent banner on your website. If you choose a banner provided by a Google-certified partner (see examples below), make sure you enable consent mode in the banner settings.

If you decide to build your own banner (not-advised), implement consent mode manually.

At the core of this issue is ensuring that you have a compliant cookie acceptance platform in place.  That will make things a lot easier to implement.  Good luck and drop me any comments or questions below.

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