Italy's Garante requires consent for email tracking pixels

What changed

Guidelines from the Garante require organizations using tracking pixels in marketing emails to obtain prior, free, specific and informed consent before the pixel collects information about whether and when a recipient opened the email. A pixel that can be traced back to a single recipient is treated as a tracking technology subject to the same consent standard as website cookies. The guidelines rest on Article 122 of the Italian Privacy Code, which implements Article 5(3) of the ePrivacy Directive. The compliance period ended on October 29, 2026, and the Garante has included verification of these guidelines in its planned inspections for the second half of 2026.

Source: View the official source

Why it matters

• Open tracking in marketing emails sent to recipients in Italy now requires prior consent.
• Pixels traceable to a single recipient follow the same consent standard as website cookies.
• The compliance period has ended and the Garante plans inspections in the second half of 2026.