Email open tracking becomes a consent attribute
Open and click tracking in email moves from an account setting to a per-recipient consent attribute, driven by the French and Italian regulators.
The pattern so far
The CNIL recommendation on email tracking pixels and the Garante guidelines, with a compliance term ending on 29 October 2026, turned open tracking into something that depends on the recipient's consent. Klaviyo tested it in July, MoEngage shipped the first native consent management for the pixel in August, and in September Adobe Campaign, Klaviyo, Account Engagement and Iterable followed with toggles and per-recipient controls.
Trajectory
Month by month
- Accelerating Reconstructed
Four vendors added controls in one month. Adobe Campaign's web interface gained a direct open-tracking toggle, Klaviyo shipped click tracking that can be disabled per recipient based on consent, Account Engagement documented a switch for open and click tracking, and Iterable documented per-recipient pixel consent.
- Emerging Reconstructed
MoEngage shipped Email Open Tracking Consent Management, built against the CNIL recommendation and the Garante guidelines, with a per-recipient consent attribute stored separately from email subscription. The French recommendation and Q&A and the Italian guidelines, with their 29 October term, set the deadline the vendors are working to.
Before it became a pattern
Early sightings that did not yet pass the entry rule on their own.