What Can Publishers Expect from Google’s New TCF Consent Collection Rules?
Unpack Google's new CMP requirement for ad serving in the EEA and UK. Learn its impact on your ad monetization strategy and how you can adapt.
Božo Janković

In the ever-evolving world of mobile app monetization, staying updated with the latest rules and regulations is crucial. If you're a publisher or developer using Google's advertising services like AdSense, Ad Manager, or AdMob, there's a significant update you need to be aware of.

Google has announced that everyone using Google AdMob, Google AdManager, or Google AdSense will have to collect consent from users via Google-certified consent management platforms (CMP), effective later in 2023

This requirement directly impacts how you serve ads to your users, specifically those located in the European Economic Area (EEA) and the UK. In essence, this means that when you're showing ads to your users in these regions, you'll need to use a specific platform to manage user consent. This platform must adhere to certain standards set by both Google and the IAB.

This might sound a bit complex but don't worry. We're here to break it down for you, explain what these changes mean, and guide you through what you need to do next. So, let's dive in and explore this new requirement in more detail.

What Does Google’s New Consent Collection Rule Mean for Publishers?

Consequently, publishers that have previously used simple implementations (pop-ups displaying Terms of Service and Privacy Policies) will no longer be able to comply with this announcement. Rather, publishers will need to collect consent from users through a Google-approved CMP that is TCF-compliant

We can expect other networks to follow Google's lead on this soon, so there's really no way to avoid it. It has already been required for ad providers such as Amazon Publisher Services, Yahoo, and Smaato to implement TCF.

In practice, publishers will need to collect consent in a more detailed way, providing users with more options and information on the data they are disclosing.

Defining Key Terms 

The Transparency and Consent Framework (TCF) was developed by the International Advertising Bureau (IAB). 

It is designed to help create a standardized approach for collecting user consent for personal data use in a manner that is compliant with GDPR (General Data Protection Regulation), which took effect on 25th May 2018.

GDPR requires that consent be freely given, specific, informed, and unambiguous. The most recent version of this framework is TCF 2.2.

As of now, 32 mobile-specific CMPs (Consent Management Platforms) are certified by the IAB. Unofficially, Google expects 3-5 CMPs to be approved by June. Google has published a list of CMPs they've currently certified, which you can follow at this link. Publishers can create their own CMP, but they would need Google's approval. 

Based on the fact that only two of the 32 CMPs currently certified by IAB come from mobile games - one from Outfit7 and one from EasyBrain - it is easy to understand how widespread TCF is in mobile games and how interested publishers have been in creating their own CMP. 

As an intermediary between publishers, end users, and vendors, a CMP provides the following:

  • Allows users to see which vendors a publisher works with.
  • Gives insight into the purposes and legal basis regarding how vendors will use the data (this link includes details on purposes and features). 
  • Stores consent signals in the user's browser, such as third-party cookies, and makes consent information available to vendors via the TCF v2.0 TC String.
  • Only allows vendors to use data for a particular purpose if they have indicated that they are using it via the GVL.

What Does Google CMP Consent Window Look Like?

The user can click on either “Consent” or “Manage options”. Clicking on Manage options will reveal a lot of additional information and options. 

This interaction produces a string that represents a more complex consent signal.

What Are Big Game Companies' Consent Practices?

As part of our study, we examined 25 big mobile video game companies and how they handle new users' pop-up experiences. Only 20% of the companies, or 5 of them to be specific, have TCF implemented. Considering what we know and what we have seen in their games, we believe those are Outfit7, EasyBrain, Rovio, Gameloft, and Supersonic Studios.

While the sample is not very large, it represents a variety of developers, including hyper-casual, casual, and core games, as well as games relying almost entirely on advertisements.

We found that most big companies haven't implemented TCF in their games yet based on the ones we checked (one for each company), including: 

  • Supercell,
  • Electronic Arts,
  • Ubisoft,
  • Zynga,
  • King,
  • Playrix,
  • Wildlife Studios,
  • Miniclip,
  • Peak Games,
  • Dream Games,
  • Glu Mobile,
  • Moon Active,
  • Sanqi Interactive Entertainment (13th on top grossing charts with their game Puzzles & Survival),
  • Top War Studios,
  • All hyper-casual publishers we checked, except Supersonic Studios (Lion Studios, CrazyLabs, Rollic Games, SayGames, Amanotes).

EasyBrain TCF Implementation

Gameloft TCF Implementation

What are the Potential Impacts of Google’s New TCF Requirements?

The announced changes may have a negative impact on publisher ad revenue from players in EEA and the UK regions.

There are currently two scenarios to consider:

  • We ignore Google’s requirements,
  • We implement TCF via Google-certified CMP, but the users decline to consent.

For start, we would expect Google to display non-personalized ads (NPA) instead of personalized ads (PA) in both scenarios. However, according to previous documentation about Google's CMP, personalized ads and other types of ads must meet certain criteria respectively.

EEA and UK countries account for 20% of GameBiz clients’ iOS ad revenue and 30% of their Android ad revenue. This means a total of 28% of our clients’ ad revenue in these countries comes from EEA and UK countries combined. 

A global study conducted by NewZoo found that 13% of global video game players, or 428 million people, are European. NewZoo reports that 50% of global revenue came from mobile devices in 2022. Nearly 12% of that came from Europe. Although we don't have reliable data on ad revenues alone, it's reasonable to assume that the share coming from Europe could be similar to IAP. 

As for how quickly publishers will align themselves with the new requirements, that remains to be seen, especially in light of how much of their revenue is generated in the affected region. In addition, Google and others may expand these requirements worldwide if they determine it is in their best interests.

How Should You Prepare for Google’s TCF Consent Requirements?

There is no specific timeline for the implementation of this change as of now. This will be a significant change for many developers and will have a significant impact if they are not given enough time to prepare. Therefore, it is unlikely that Google will enforce this change before Q4.

As there are so many uncertainties at the moment, it's best to gather information and explore options instead of making any decisions. Publishers will ultimately need to change their consent collection practices for both iOS and Android users.

It is likely that the industry will adapt to this change as it did to previous industry changes, such as the introduction of ATT popups or the still fresh real-time bidding shift. However, given that users will be faced with yet another pop-up, the question of whether their privacy and user experience will improve or not is up for debate.

If you have experience with implementing these changes or need help navigating them, feel free to reach out to GameBiz Consulting. With years of experience navigating the ad monetization industry, we can help you come up with a tailored solution to implementing new consent collection forms in order to minimize the negative impact on your revenue.

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