Consent Mode is a system developed by Google to ensure that web users’ cookie preferences, as set in third-party cookie consent banners, are properly implemented by Google services such as Google Analytics and Google Ads.
In practice, this means that the behaviour of Google’s tracking tags is modified by those preferences, to the point that they are deactivated when users have not opted in to them.
Consent Mode was first established in 2020 and was substantially revised in the guise of version 2, which was launched late in 2023.
Websites that have a cookie opt-in banner from a participating partner are compatible with Consent Mode. Consent Mode does not provide its own cookie banners, and can only be used with third-party ones for which integrations have been developed.
This also means that not having a third-party cookie banner effectively excludes your website from implementing Google Consent Mode.
Until recently, many websites have quite legitimately considered cookie consent banners to be unnecessary when the only cookies they collect are essential or in the legitimate interest of directly marketing to the customer concerned.
However, both the Information Commissioner’s Office in the UK, and the equivalent organisation governing web privacy in the EU, have come to the view that some Google services, such as Analytics, require user consent and are not covered by the allowance for legitimate interest in the General Data Protection Regulation.
This development has prompted Google to react by launching its Consent Mode software to allow it to operate in liaison with cookie banners and act on their users’ cookie choices.
Consent Mode does not automatically work with all cookie banners, but Google has launched what it calls its CMP Partner Program, allowing the makers of Consent Management Platforms to work with it to allow Google Consent Mode functionality via those platforms.
Moreover, in January 2024, Google announced that it would make the use of Consent Mode mandatory by March 2024 for any websites using personalised Google-mediated advertising features, such as those available in Google Ads campaigns. This announcement does not by itself indicate that Consent Mode is compulsory for using Google Analytics, but it seems possible that Google will tighten its requirements for the use of Consent Mode into areas beyond personalised advertising in the future.
What are the drawbacks to implementing Google Consent Mode on my website?
The main drawback is that implementing Google Consent Mode may require you to change your tracking protocol completely to one centred upon Google Tag Manager. This is a sophisticated tagging system that is, however, quite demanding to learn, and is likely to be too complex to implement for most small businesses running their own websites on a DIY basis. Implementing GTM properly is likely to be a job that will need to be outsourced to a dedicated digital agency or other IT expert with experience of the system, and this will come with a cost attached.
The second potential drawback is that if you do not already use a cookie management platform or use one that does not have an established integration with Google Consent Mode, you may need to implement a new cookie management platform on your site, one that has such an integration available. This will also take time and may involve third-party agency fees to implement, and if you are of the school of thought that cookie pop-ups are intrusive and bad for user experience, then you are probably not going to be pleased about having to implement one at all in order to access Google Consent Mode.
What are the changes to Google Consent Mode in version 2 compared with version 1?
Both versions of Consent Mode modified Google’s tracking behaviour for both Analytics and advertising purposes based on user preferences, with Version 1 being held up to behave in a ‘consent-aware’ fashion; but version 2 is said to adopt a stricter approach to avoiding all cookies that serve these functions unless the user has given specific consent to them.
In version 2, simple two-way software switches codenamed ad_user_data and ad_persoanlization record the fact of user consent or its absence in relation to the sharing with Google of users’ data and the serving by Google of personalised advertising to them, respectively.
What is the Difference between Basic Consent Mode and Advanced Consent Mode?
Basic Consent Mode automatically blocks the implementation of Google Tags prior to a consent signal being received by Google from the cookie management platform on your website. Thus, it ensures compliance with the strictest interpretation of EU privacy and data-processing directives
Advanced Consent Mode automatically preloads Google tags prior to the user giving consent, but then modifies Google’s tracking behaviour depending on how the user responds to the cookie management platform. This order of processes could rightly be seen as less strictly compliant with EU regulations than Basic Consent Mode, and is not recommended for businesses wanting to insure themselves against possible lawsuits from privacy campaigners or opportunists.
Furthermore, when you use Advanced Consent Mode, Google continues to collect user data using a protocol known as cookieless pings, which is switched off under Basic Consent Mode. Although Google claims that this ping data is only used for collective data aggregation purposes that serve its Analytics platform, it is again taking a more liberal interpretation of EU rules than would be allowed for by Google’s behaviour under Basic Consent Mode.
Advanced Consent Mode also gives the webmaster more control over Google’s behaviour, which can potentially be customised to allow for more tracking or less tracking.
If I don't run Google Ads campaigns or host Google AdSense advertising on my website, does it need Consent Mode V2?
If you don’t either have an active Google Ads account or host Google AdSense advertising on your website, then Google itself will not require you to use Consent Mode in order to access the targeted advertising benefits of these programmes.
However, you might still consider that it is a good idea to use Google Consent Mode in order to give your customers full confidence in the extent of your implementation of EU and UK privacy directives. In other words, there could be customer relations advantages to doing so.
Do I need Consent Mode V2 to carry on using Google Analytics 4?
Regulatory authorities have repeatedly stated that express consent should be required for analytics data collection. If you don’t use Google Consent mode but continue to use Google Analytics or a similar platform, there’s a risk that you could be perceived by some customers as violating their rights to data privacy.
This said, it is worth remembering that any cookie management platform (with or without Google Consent Mode) that requires the user to opt in to analytics data collection will tend to reduce the accuracy of the data collected and displayed by website activity-monitoring tools such as Google Analytics, because the majority of users will be likely in most cases not to elect voluntarily to opt in to having their data collected.
Every webmaster now has a choice to make in terms of prioritisation, between the directive to satisfy the most privacy-conscious customers (as well as the Information Commissioner’s Office) of compliance with the strictest interpretations of privacy laws, and the commercial interest of obtaining accurate aggregated data via platforms such as Google Analytics.
Although Google Analytics 4 aims by design to meet some of the key regulatory objections to the previous iteration, Universal Analytics, it remains controversial in some quarters, and there is a risk that using it without the accompaniment of Consent Mode will be negatively perceived. And even though Google has not yet made its usage contingent upon also enabling consent mode, there is no guarantee that it will not do so within the next few years.
In the meantime, if you do not use the latest version of Consent Mode, certain features of Google Analytics 4 related to demographic tracking and analysis may be unavailable because of Google wanting to protect its own back against costly lawsuits and fines by the regulatory bodies.
If you need help or guidance on implementing Google Consent mode to support your marketing and Google Ads campaigns, we'd love to hear from you.
