EDPB Issues Guidance on Consent and “Pay-or-Consent” Models

The European Data Protection Board (EDPB) has issued updated guidance clarifying how GDPR consent rules apply to “pay-or-consent” models used by online platforms. These models require users either to pay a fee or consent to extensive personal data processing.

The EDPB emphasizes that consent must be freely given, meaning users must have a genuine choice and not be coerced into consenting due to economic pressure. Controllers must assess whether alternative options truly preserve user autonomy.

This guidance has major implications for digital publishers, ad-tech providers, and subscription platforms. DPOs and privacy advisors must now reassess consent mechanisms, cookie banners, and subscription architectures to ensure compliance.

Official source:
European Data Protection Board – Guidelines on Consent
https://www.edpb.europa.eu/our-work-tools/our-documents/guidelines_en