- What is TCF v2.2
- Consent banner changes within TCF v2.2
- Vendor list changes
- Migration instructions for TCF v2.2
What is TCF v2.2?
In summary, the TCF v2.2 brings several important changes to the digital advertising industry by expanding the scope of the framework, updating the UI requirements for CMPs, introducing policy changes, enhancing accountability and transparency requirements, and updating technical specifications. These updates are designed to give users more control over their consent choices, increase transparency and accountability, and improve the overall user experience. The IAB has given CMPs and publishers until November 20, 2023 to implement the new policies and specifications.
Who is this for?
The TCF integration is intended for organisations that rely on ad revenue from their website(s) and must have their end user’s consent before being able to use targeted advertising.
We recommend discussing internally whether or not you need to implement Cookiebot CMP with support for the Transparency & Consent Framework.
Consent banner changes within TCF v2.2
To align with the updates in TCF v2.2, the Cookiebot banner will undergo the following modifications:
- Vendor Count: The Cookiebot CMP will show the combined number of IAB and non-IAB vendors on the initial layer and the ad-settings layer.
Vendor Information Disclosure: Any new information provided by vendors will be made transparent to the end users. At the ad-settings layer, we will include:
- Categories of the data collected.
- Retention periods, specified for each purpose.
- Links that provide further insight into legitimate interests, where relevant.
- Opt-in and opt-out: It's mandatory for all CMPs to provide both opt-in and opt-out options. Notably, the Cookiebot CMP already includes these features.
Vendor list changes
With the launch of TCF 2.2, the new vendor list will be introduced. As vendors add more information to this list, the TCF framework will provide greater transparency and clarity for site visitors. The updated vendor list will be referred to as Version 3 and will be consistent with the TCF Policy Version 4.
You can view the current global vendor list and all its details here.
The latest vendor list brings several changes regarding vendors and their purposes. In particular, it removes "legitimate interest" as a legal basis for advertising and content personalization (purposes 3, 4, 5, & 6). It also adds a new purpose has been added (purpose 11): "Use limited data to select content."
Migration instructions for TCF v2.2
The process for migrating to TCF v2.2 varies depending on the implementation method you choose. Below are detailed instructions for:
- Implementation via direct script implementation,
- implementation via Google Tag Manager,
- Implementation via the Cookiebot WordPress Plugin.
Direct script implementation
For a direct script implementation, the primary change requires a minor update to the IAB attribute in the Cookiebot script. To make this change, simply replace the value of the data-framework attribute from
Implementation example for TCF v2.2:
Implementation via Google Tag Manager
We are introducing an option in our Google Tag Manager (GTM) template to accommodate those who wish to migrate to TCF v2.2 using GTM.
- Update your existing Cookiebot GTM template.
- In the updated interface, you'll notice a drop-down menu below the checkbox in a newly introduced section. Select version v2.2 from this menu to activate the change.
Implementation with the WordPress plugin
Log in to WordPress: Start by logging in to your WordPress account.
Update the Cookiebot CMP plugin: Make sure you have upgraded your Cookiebot CMP plugin to the latest version, at least version 4.3.
Navigate to the settings: Once updated, open your Cookiebot CMP plugin and go to "Settings."
Access the IAB tab: From the settings, go to the IAB tab.
Select the TCF version: In this section, you'll notice a new option to specify the TCF version. Select "TCF v2.2" from the available options.
Save changes: Confirm and save your changes. This action will automatically switch you to the TCF 2.2 version.
Deprecation of the “getTCData” command
TCF version 2.2 deprecates the “getTCData” command. If you are currently using the “getTCData” command in any implementation, it's important to switch to the event listener feature. For full details on the event listener implementation, please see our support article: : Troubleshooting Common IAB TCF V2.0 Errors.
Why do I need to migrate to TCF v2.2?
There are several reasons why you should migrate to TCF v2.2:
- TCF v2.2 includes enhancements that give users more transparency and control over their data preferences, in line with evolving data privacy regulations.
- Staying current with the latest version ensures compliance with industry standards and builds trust with users and partners alike.
- TCF v2.2 provides publishers with greater flexibility to communicate user choices to third parties, improving the overall consent ecosystem.
- After November 20, new TCF strings created under TCF 2.0 will no longer be valid. This will result in no ads being displayed to your visitors.
Does migration always trigger a renewal of consents?
Generally, migrating from TCF v2.0 to TCF v2.2 does not require a consent renewal, which means that the consent banner does not automatically need to be re-displayed. A primary reason for consent renewal would be significant changes in your vendors and their purposes.
However, because you, as our valued customer, maintain control over your vendor list and associated purposes via the publisher restriction script add-on, we won't automatically trigger a consent renewal.
It's important to carefully consider any changes to your vendor selections and their respective purposes. This will also depend on any vendor or purpose restrictions you may have made within your implementation. Let's take a look at an example of a vendor change that would require a resurfacing:
- Vendor-ID: 15
- GVL-Version 2:
- Purposes: 1,2,3,4,5,6,9,10
- GVL-Version 3:
- Purposes: 1,2,3,4,5,6,9,10,11
- GVL-Version 2:
- In this case, the vendor selected within your implementation has added one additional purpose (purpose 11). If you have this vendor implemented, this would require a resurface.
For your convenience, we've provided a list of vendors with updated purposes, which you can view here. Please be aware that the version of the vendor list is indicated at the top of the document, as purpose changes can vary between different vendor lists.
If a consent renewal becomes necessary, follow these steps:
- Navigate to the Cookiebot manager.
- Access the "User consents" tab.
- Select your domain.
- Click “Renew now” in the lower right corner.
If you're unsure about the need for a renewal, our advice is to opt for a consent renewal to ensure compliance.
Will existing TCF 2.0 strings be valid after November 20, 2023?
Yes, all existing TCF v2.0 strings that were created before November 20, will remain valid after that date, unless you renew the consent. However, keep in mind that this TC string will only consent to vendors based on the TCF v2.0 vendor list. If a user on your website changes or withdraws their consent, they will see the content of the new TCF v2.2 vendor list within the consent banner.
This way, we always ensure that new consents and changes will be applied based on TCF v2.2. We are aware that this may lead to a lack of transparency regarding a customer's current consent selection. If you are concerned about this lack of transparency, we recommend that you renew your consents.
What are the consequences of not migrating by November 20, 2023?
If you do not migrate by the required deadline of November 20, 2023, any TC strings obtained under TCF v2.0 after that date will be considered invalid. This could adversely affect your agreements with advertisers, potentially resulting in a decrease in your ad revenues.
To protect you from these potential pitfalls, we are implementing a change to our CMP script. This will facilitate an automatic migration from TCF v2.0 to TCF v2.2 on November 20, 2023. However, we strongly recommend that you do not rely solely on this auto-update. Taking proactive steps will ensure a smoother and more reliable transition for your site.