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ePrivacy

The Regulation that was going to replace this was withdrawn in 2025

For years, digital marketing compliance was discussed as though the current rules were transitional. They are not. The proposal that would have replaced them was formally withdrawn, and the Directive of 2002 remains in force.

The proposal for an ePrivacy Regulation was published in 2017 and negotiated for eight years. It was formally withdrawn by the European Commission, with the withdrawal published in the Official Journal in October 2025, on the grounds that no agreement was in prospect and that the proposal had been overtaken by legislation adopted in the meantime.

The practical consequence is worth stating plainly, because a great deal of planning assumed otherwise. Directive 2002/58/EC continues to apply, as transposed by each Member State, with all the national divergence that article 13(3) permits. The divergence is not a transitional inconvenience awaiting harmonisation; it is the settled state of the law.

What still governs digital marketing

MatterInstrumentHarmonised?
Consent for automated calls, fax and emailArticle 13(1) of Directive 2002/58/ECYes
Existing-customer exceptionArticle 13(2)Yes, with four cumulative conditions
Consent or objection for other communicationsArticle 13(3)No — left to national law
Storage of information on terminal equipmentArticle 5(3) of Directive 2002/58/ECYes in principle; national implementations vary
Right to object to direct marketingArticle 21(2) and (3) of Regulation (EU) 2016/679Yes, and unconditional
Identification of commercial communicationsDirective 2000/31/EC and national transpositionsYes
What this changes for planning

Organisations that deferred building a per-market consent architecture, in the expectation that a Regulation would make one unnecessary, now have to build it. The instrument that would have removed the need no longer exists, and no replacement has been proposed.

What this site addresses

Each has a concrete answer on the solutions page.

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