Interactive Advertising Bureau

TCF v2.2 - Implementation FAQs

Yes, although the TCF Policies do not require that CMPs provide a call to action for users to refuse consent from the first layer of their UIs, nothing in the TCF Policies is intended to prevent going beyond these minimum requirements. As with any other design requirements that are not specified by the TCF policies, publishers should ensure they are fully aware of their local Data Protection Authority’s requirements and act accordingly.
Yes, the TCF Policies do not request all user interfaces (UI) to take the form of a popup overlay. This is only required in connection with requesting users’ consent, in which case the UI needs to be displayed prominently and separately from other information. When making use of a so-called layered approach, publishers and their CMPs may choose to provide transparency
and the right to object relating to Purposes or Special Purposes pursued by Vendors on the basis of their legitimate interests in a separate webpage, such as in their privacy policies, so long as users are provided with an easily accessible link to it from the UI that is used to request their consent.

Because such an approach can impact a commercial CMP’s ability to assume responsibility for compliance with the TCF Policies, publishers may be required to register a private CMP and use a commercial CMP’s offering in association with their private CMP ID in line with Chapter II: Policies for CMPs (7)(2).
Data Protection Authorities have issued different guidelines and recommendations on the appropriate duration - which varies between 6 months to 24 months. The TCF v2.2 Policies take into account these discrepancies and require publishers to remind users of their choices according to the requirements laid down by publishers’ local regulator(s).

To help TCF participants in their implementation, the below table provides the best practice recommendations that have been provided so far by certain national regulators (last updated March 2024):

Best Practice Recommendation
DATE6 Months
SUBJECTCzech Republic
DATE6 Months
DATE12 Months
DATE24 Months
IAB Europe
Rond-Point Robert
Schuman 11
1040 Brussels
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