August 9, 2025
2 min read
The IAB Transparency and Consent Framework (TCF) v2.2 introduces substantial modifications focused on strengthening user rights and addressing regulatory feedback, notably from the Belgian Data Protection Authority. The principal revision is the elimination of “legitimate interest” as a legal basis for advertising and content personalization, which directly addresses regulatory concerns about the sufficiency of user consent (IAB Europe, 2023). Industry participants can now only rely on explicit consent for these activities, which marks a significant shift in digital advertising practices.
Further, TCF v2.2 mandates enhanced transparency in user-facing disclosures. CMPs must now provide plain-language descriptions for each purpose and feature, replacing previous legalistic language. This change aims to facilitate genuine informed consent by ensuring users understand how their data will be processed (European Data Protection Board Guidelines, 2020). Additional requirements include disclosure of:
The first layer of the consent management interface must now display the total number of vendors requesting consent, increasing transparency regarding third-party participants in the data ecosystem. Furthermore, the framework obliges CMPs to implement UI features that allow users to easily recall the cookie banner and withdraw consent at any time, aligning with GDPR’s emphasis on continuous user autonomy.
All consent management platforms (CMPs) and vendors participating in TCF are required to comply with these standards by September 30, 2023. The updated requirements are expected to foster greater user trust by providing clear, actionable choices and comprehensive information about data processing. Early industry reports indicate that while there is an increased compliance burden, both user engagement with consent banners and withdrawal rates have improved as a result of these changes.
