# [Cookiebot response to the new German consent management regulatory ordinance](https://www.cookiebot.com/en/response-to-new-german-consent-management-regulatory-ordinance/) **Munich, February 7, 2025** - As the leading European CMP provider, we strongly believe in the importance of privacy and data protection. Every European citizen has the fundamental right to control their personal data. At Usercentrics, we are committed to supporting an online experience that empowers individuals while fostering trust and transparency. · [Press release (PDF)](https://www.cookiebot.com/en/wp-content/uploads/sites/7/2025/02/Press-Release-Usercentric-Response-to-the-new-German-consent-management-regulatory-ordinance.pdf) --- ## Current approaches and concerns We appreciate the initiative of German legislators to introduce more standardized consent signaling from users. However, we also have significant concerns, especially when looking into the still nebulous requirements for these services and the different approaches a consent management service could take. ### Reliance on user identifiers One principle of privacy-first design is minimizing reliance on shared user identifiers across services. Current solutions often depend on networks requiring user logins, where consent preferences are tied to a user ID. Consent preferences under the connected user ID are then shared with partners within these networks, and consent decisions rely on the shared user ID. ### Issues with generalized prior consent for users ### Issues with generalized prior consent for controllers ### Issues with reliance on third-party tools to achieve ordinance goals ### Complex and evolving ecosystem requirements --- ## Challenges for compliance and user experience The current ordinance introduces confusion about how Consent Management Services should function in practice. The approach suggests that individuals could make general decisions through third-party tools, which would then transfer consent preferences to each website’s CMP. --- ## Opportunities to evolve solutions, compliance, and user experience The ordinance recognizes the need to reduce the overwhelming number of consent prompts that users encounter daily via banner or pop-up displays. The GDPR also requires that users must be able to exercise choice freely, including revoking consent as easily as it was given. User-friendliness is therefore also an important consideration for CMPs and for other Consent Management Services. ### Complex and evolving ecosystem requirements The consent ecosystem is inherently complex — across Europe and around the world — involving diverse legal frameworks and, increasingly, policy requirements from large tech platforms. To meet these requirements advanced systems must: - Clearly guide users through data processing information, user rights, and consent decisions with user-friendly interactions to build trust - Equip website providers with tools to securely collect, document, manage, and signal granular consents - Enable ongoing compliance with legal requirements for explicit, informed, and granular consent --- ## Usercentrics recommendations It is essential to strengthen user-centric solutions to address these challenges in a way that is privacy-compliant and embraces privacy by design. Regulators, website operators, and consent management vendors should prioritize tools that enable users to manage their consent preferences directly within their devices or browsers. Open standards for consent signaling can further enhance user autonomy and transparency, creating an enhanced, user-friendly, and trustworthy environment. ***Published by:** Eike Paulat, Director Product and Theodora Zamanakou, Senior Legal Counsel* **About Usercentrics** Usercentrics is a global market leader in solutions for data privacy and Privacy-Led Marketing. We believe in creating a healthy balance among data-driven business and Privacy-Led Marketing to unlock sustainable growth for every size of enterprise. Cookiebot CMP is our plug-and-play SaaS, our App CMP handles user consent on mobile apps, and Usercentrics Web CMP serves companies with enterprise-grade custom requirements for unifying consent and data from capture to processing. Helping clients like Daimler Truck AG, ING, and Konica Minolta achieve privacy compliance, Usercentrics is active in 195 countries on more than 2.3 million websites and apps, with 5,400+ resellers, and handles more than 7 billion daily user consents. **Press contact:** Hannah Sinz, Sr. PR Manager, [email protected] --- ## Product [Cookiebot™ Consent Solution](https://www.cookiebot.com/en/cookie-consent-solution/) · [Usercentrics for Wix](https://www.cookiebot.com/en/cookiebot-for-wix-by-usercentrics-app/) · [WordPress Plugin](https://www.cookiebot.com/en/new-wp-cookie-plugin/) · [Pricing](https://www.cookiebot.com/en/pricing/) ## Regulations [DMA (EU)](https://www.cookiebot.com/en/digital-markets-act-dma/) · [GDPR (EU)](https://www.cookiebot.com/en/gdpr/) · [CCPA (California)](https://www.cookiebot.com/en/what-is-ccpa/) · [VCDPA (Virginia)](https://www.cookiebot.com/en/virginia-vcdpa/) · [LGPD (Brazil)](https://www.cookiebot.com/en/lgpd/) · [TCF v2.3 (IAB)](https://www.cookiebot.com/en/tcf/) · [Google Consent Mode](https://www.cookiebot.com/en/cookiebot-cmp-google-consent-mode/) · [Microsoft UET Consent Mode](https://www.cookiebot.com/en/microsoft-consent-mode-cmp/) ## Partners [Become an affiliate](https://www.cookiebot.com/en/affiliates/) · [Become a partner](https://www.cookiebot.com/en/resellers/) · [Find a partner](https://www.cookiebot.com/en/cookiebot-reseller/) ## Resources [Blog](https://www.cookiebot.com/en/blog/) · [Digital Markets Act Hub](https://www.cookiebot.com/en/digital-markets-act-dma-resources/) · [Google Consent Mode Hub](https://www.cookiebot.com/en/google-consent-mode-resources/) · [Google Consent Mode V2 Certification](https://courses.usercentrics.com/course/google-consent-mode-v2) · [Google Consent Audit Fixes](https://www.cookiebot.com/en/google-consent-audit-fixes/) · [Developer documentation](https://www.cookiebot.com/en/developer/) · [Cookiebot vs CookieYes](https://www.cookiebot.com/en/cookiebot-best-cookieyes-alternative/) · [Cookiebot vs OneTrust](https://www.cookiebot.com/en/onetrust-alternative/) · [Cookie Banner Cost Calculator](https://www.cookiebot.com/en/cookie-banner-pricing-calculator/) ## Company [About us](https://www.cookiebot.com/en/about/) · [Careers](https://usercentrics.com/career/) · [Support](https://support.cookiebot.com/hc/en-us/) --- [Privacy Policy](https://www.cookiebot.com/en/privacy-policy/) · [Terms of Service](https://www.cookiebot.com/en/terms-of-service/) · [Cookie Declaration](https://www.cookiebot.com/en/cookie-declaration/) · [Data Processing Agreement](https://www.cookiebot.com/en/data-processing-agreement/) ©2026 Cookiebot™ by [Usercentrics](https://usercentrics.com/)