Consent Mode v2 and the DMA: A Practical Guide for EEA Advertisers

On 7 March 2024, the European Commission announced that the six designated gatekeepers, including Alphabet and Meta, had to comply with all obligations under the Digital Markets Act (DMA) ¹. The same month, Google began enforcing updated consent requirements for traffic from the European Economic Area (EEA), built around Consent Mode v2 ². More than two years on, many advertisers still treat consent as a legal box to tick. In practice it now decides whether Google Ads can measure, bid and build audiences for European users at all.

This guide explains what Google requires, how the two implementation modes differ, what modelling can and cannot recover, and how to check a setup.

What Consent Mode v2 actually is

Consent mode is a way of passing a user's consent choices to Google tags. It does not provide a banner itself: it works alongside the consent banner already on a site ³. Version 2 added two signals to the original pair, giving four consent types ⁴:

Consent type	What it controls
ad_storage	Storage such as cookies or device identifiers related to advertising
analytics_storage	Storage related to analytics, for example visit duration
ad_user_data	Consent for sending user data to Google for online advertising
ad_personalization	Consent for personalised advertising

The two newer signals, ad_user_data and ad_personalization, are the ones Google tied to personalised advertising and remarketing in 2024 ². They also apply outside the website tag. For Customer Match lists from the EEA, both must be set to "GRANTED", and if they are missing the user is treated as not having consented ⁵.

Who has to comply, and where

Google's EU user consent policy applies to end users in the EEA, the UK and Switzerland. Switzerland was added on 31 July 2024 ⁶. The obligations differ by region, however:

• EEA traffic: advertisers must pass end-user consent choices to Google, for example via consent mode or the IAB Transparency and Consent Framework (TCF), and the signals must reflect what users actually chose ⁶.
• UK and Swiss traffic: consent is still required where the law demands it, but Google states it does not expect advertisers to send a verified consent signal for these users ⁶.
• Advertisers based outside Europe are covered too if they reach users in these regions. The policy follows the user's location, not the advertiser's.

Google's help page also notes a newer change: beginning in August 2026, Google will start launching IP-based ads measurement and personalisation in these regions, using IP addresses received through tags, SDKs and uploads. It suggests advertisers explain this in their consent banner where applicable ⁶.

What happens if you get it wrong

Google warned in early 2024 that advertisers must collect consent "to keep using measurement, ad personalisation and remarketing features" ². Enforcement has since become visible. In July 2025, PPC Land reported emails in which Google told some advertisers their sites did not comply with the EU user consent policy and that it would disable "personalised and non-personalised ads, remarketing and conversion tracking functionality" ⁷.

The rules have also kept moving. A June 2026 analysis by Usercentrics explained that from 15 June 2026, ad_storage alone governs whether advertising data from the Google Analytics tag flows into Google Ads, rather than sharing that role with the Google Signals setting ⁸. Small changes like this can quietly alter what data reaches campaigns.

Basic versus advanced consent mode

The choice of implementation affects how much measurement survives when users decline.

• Basic mode: Google tags are blocked until the user interacts with the banner. If the user does not consent, no data is sent to Google at all, not even the consent status. Modelling relies on a general model ⁴³.
• Advanced mode: tags load when the page opens, with consent denied by default. While consent is denied, the tags send cookieless pings; full measurement data is sent only once the user grants consent. This enables an advertiser-specific model rather than a general one ⁴³.

Advanced mode gives better modelling, but it means some signal is sent to Google before consent is given. Whether that is acceptable is a decision for the organisation's legal and privacy advisers, not only the marketing team.

How modelling fills the gaps

When users decline cookies, Google uses modelling to estimate the conversions it cannot observe. In Google Ads, conversion modelling uses observable data and historical trends to estimate the share of unconsented conversions that came from ads, and modelled conversions appear in the standard Conversions column ⁹. Google notes that consented users are typically 2-5 times more likely to convert than unconsented users, and that modelling is most accurate when cookieless pings are fired ⁹.

Modelling has entry thresholds:

• Google Ads: consent mode or TCF must be correctly implemented, with at least 700 ad clicks over seven days per country and domain grouping ⁹.
• Google Analytics 4: at least 1,000 events per day with analytics_storage denied for at least seven days, and at least 1,000 daily users with analytics_storage granted for at least seven of the previous 28 days ¹⁰.

Smaller advertisers may not meet these, which means basic mode plus low consent rates can leave large gaps in reporting.

Choosing a consent management platform

Publishers serving personalised ads in these regions must use a Google-certified CMP integrated with the TCF. Advertisers are encouraged to work with a CMP from Google's partner programme but are not required to, and Google notes that using one does not by itself guarantee compliance ⁶. Many CMPs send the consent state to Google automatically ⁴, which reduces the risk of tagging errors.

Practical setup checklist

1. Confirm which regions your traffic comes from and which rules apply to each ⁶.
2. Choose a CMP and make sure its banner covers advertising, analytics, data sharing with Google and, where relevant, IP-based measurement ⁶.
3. Set default consent states before any Google tag fires, with denied defaults for EEA users.
4. Decide on basic or advanced mode with your privacy advisers ⁴.
5. Check that all four consent types are passed on every page and app screen ¹⁰.
6. Pass consent for offline and Customer Match uploads, not only for website tags ⁵.
7. Review the consent diagnostics in Google Ads and GA4, and recheck after any site release or CMP update.

Key takeaways

• Consent Mode v2 adds ad_user_data and ad_personalization to the original storage signals ⁴.
• Verified consent signals are required for EEA traffic; the UK and Switzerland are covered by the policy without that expectation ⁶.
• Google has disabled ads features for some non-compliant accounts, according to 2025 trade press reports ⁷.
• Advanced mode enables advertiser-specific modelling, but modelling only starts above set traffic thresholds ⁹¹⁰.
• The rules continue to change, including IP-based measurement from August 2026 ⁶.

What this means for your brand

Treat consent as part of your measurement design, not a legal afterthought. Audit your banner, CMP and tag configuration together, because a failure in any one of them can cut off conversion data and audiences in Europe. If your volumes are below modelling thresholds, focus on raising genuine consent rates through clearer banners and a better value exchange. Schedule a quarterly review, since Google has changed how these signals work more than once since 2024.

Sources

1. Designated gatekeepers must now comply with all obligations under the Digital Markets Act - European Commission, March 2024
2. Consent Mode V2: Google Shares Key Details For Advertisers - Search Engine Journal, February 2024
3. About consent mode - Google Ads Help, 2026
4. Consent mode overview - Google for Developers, July 2026
5. How to provide consent for Customer Match - Google Ads Help, 2026
6. Help with the EU user consent policy - Google, 2026
7. Google disables conversion tracking for non-compliant EU advertisers - PPC Land, July 2025
8. Google Signals and Consent Mode: What Changed in 2026 - Usercentrics, June 2026
9. About consent mode modeling - Google Ads Help, 2026
10. GA4 Behavioral modeling for consent mode - Google Analytics Help, 2026

Figures and product details are as reported by the sources listed, at the time of writing. Platforms change quickly, so check the latest documentation before acting on any single number.