French data protection authority establishes heightened consent rules for tracking pixels in emails

The French Data Protection Authority (CNIL) released guidance on April 14, 2026 on the use of invisible tracking pixels in electronic mail. The guidance adapts to pixels a strict interpretation of cookie consent rules and reflects a very narrow view of the circumstances in which pixel tracking in emails can occur without prior consent. Because requiring prior consent for pixel tracking represents a material shift in regulatory expectations, this guidance has immediate implications for email... By: Hogan Lovells