Navigating Google's New User Consent Requirements
In this article, we'll explain what the new Google TCF and CMP requirements are and how they may affect your ad monetization strategy in 2023.
Božo Janković

The mobile game industry has witnessed a dynamic transformation over the past two years, marked by pivotal shifts such as the implementation of IDFA, Google’s transition to real-time bidding, and stricter interstitial ad implementation requirements.

These changes, coupled with the still-uncertain socio-economic situation, have collectively redefined the trade of monetizing games through ads. A recent development from Google has stirred the industry further by introducing new TCF-compliant (Transparency & Consent Framework) user consent requirements for displaying ads within the European Economic Area (EEA) and the United Kingdom.

This article delves into the heart of this evolving scenario, offering strategic insights for game publishers navigating this intricate terrain. We hope that by sharing the fundamentals of our two-month research, we can provide a comprehensive understanding of the implications of this shift and equip you with the knowledge needed to adapt to this evolving landscape and make informed decisions about refining ad monetization strategies.

TCF 2.2 Requirements’ Implementation Timeline

On May 16, 2023, Google unveiled its plan to mandate user consent collection through Google AdMob, AdManager, and AdSense, facilitated by a Google-certified Consent Management Platform (CMP). Although the initial announcement mentioned a forthcoming deadline, it has since been clarified that publishers have until January 16, 2024, to align with this requirement. 

While our discussions with ad networks and industry peers suggest a measured pace of implementation, it's important to remember the possibility of publishers delaying adoption until the eleventh hour. After all, we’ve seen this during other significant industry shifts like ATT, Apple Privacy, and GDPR.

This becomes even more plausible when we consider that as we head towards the fourth quarter of the year, publishers might be hesitant to make changes that could disrupt the most profitable time for ad earnings.

Earlier, we provided examples of ways to ask for user permission that followed TCF rules. But none of those examples meet the TCF 2.2 standard. Big game publishers like Supercell, Electronic Arts, Ubisoft, Zynga, and others have straightforward permission processes that don't exactly match TCF guidelines.

Key Insights from Google on CMP and TCF Requirements

In addition to the deadline, Google has an official list of approved Consent Management Platforms (CMPs). You can find this list at this link. Currently, there are 49 CMPs on the list. While all of them work for websites, only 21 are suitable for mobile apps, including Google's solutions. Among these, Outfit7 is the sole game publisher with an approved CMP. Another game publisher, EasyBrain, has its own CMP certified by IAB, but it's not yet recognized by Google.

It's important to note that publishers have the choice to create their own CMP instead of using existing solutions. However, this route tends to be impractical for most companies in the industry. This is due to the technical and legal complexities involved, along with a lengthy bureaucratic process. Namely, a CMP created by the developer needs to be certified by both IAB and Google, and the time required for this process is uncertain at this time.

When it comes to TCF versions, the latest introduced by IAB is TCF 2.2. The original deadline for CMPs to adopt this version was September 30, 2023, but it has now been extended to November 20, 2023.

How to Choose the Best Consent Management Platform (CMP)?

At GameBiz, we've conducted an in-depth analysis of various CMP solutions to provide you with essential insights. We began by analyzing the initial list of 11 certified CMPs and engaging in two rounds of interviews with them. The initial evaluation led us to shortlist our top five preferences, followed by a comprehensive third round of discussions to delve into the finest nuances of their product offerings. When choosing the right CMP, several factors come into play which we will list below.

Support Availability

The first factor on the list is arguably also the most important. From our experience, implementing a CMP is not an easy process. Adequate support, both during and after implementation, is crucial to avoid unintentional disruptions to your ad revenues. A single day of CMP issues can potentially cost more than a year's worth of CMP service fees.

Consent Pop-Up Customization

The flexibility to customize consent pop-ups is vital. Opting for an out-of-the-box solution versus customization can significantly influence opt-in rates, which are pivotal for preserving ad revenue streams.

AB Testing Availability

This criterion aligns with the customization aspect. CMPs offering built-in AB testing capabilities for different consent pop-up variations can markedly enhance the chances of maximizing your opt-in rates.

Regulations Supported

Consider the location of your users when selecting a CMP. While Google currently mandates TCF 2.2 consent for EEA and UK users, future regulations might encompass a wider scope and other regulations such as CCPA - California Consumer Privacy Act, LGPD - Brazilian data protection law and others. Adapting to these potential shifts could impact your choice of CMP.

TCF Version Supported

It's important to ensure the CMP you pick can keep up with changes. Checking if your chosen CMP plans to update to the TCF 2.2 requirement by the given deadline is crucial. This helps prevent any issues down the line and ensures a smooth transition as standards evolve.

Integration Options

All the CMPs we assessed require SDK integration. Depending on your game development platform (iOS, Android, React Native, Unity, Flutter, etc.), some integration options might be more convenient than others.

Server Location

While this might initially seem unconventional, server location holds major significance. Historical scrutiny of data transfers outside the European Union underscores the importance of having CMP servers located within the EU for data protection.

Server Location

Even though it might sound strange at first, examining the physical location of servers is a wise idea. There's a history of regulators being concerned about moving data outside the European Union. 

Specifically, this scrutiny revolved around the Privacy Shield mechanism, which faced challenges in EU courts and was questioned as a valid legal basis for data transfer. In response, Meta even indicated that they might need to withhold their products from EU customers, including the Facebook app, Instagram, and WhatsApp, if this mechanism is invalidated.

Notably, on July 10, 2023, the European Commission adopted a decision endorsing the adequacy of EU-US transfers, affirming that the United States maintains data protection on par with EU standards. While the current landscape seems favorable, publishers aiming for an extra layer of security may prefer to select a CMP with servers located within the EU, ensuring their data remains well-protected.

Experience with Game Publishers

When selecting a service provider, opt for those familiar with your industry. Their understanding of challenges faced by game publishers can lead to more targeted solutions that align with your specific requirements. Their expertise and industry experience can make a notable difference in achieving successful outcomes for your ad monetization strategy.

CMP as a Core Product

It's essential to recognize the difference between a provider whose primary focus is the CMP and another company with a diverse array of products. Choosing a provider whose main expertise centers on the CMP underscores their commitment to excelling in this specialized area. In contrast, companies with varied priorities may allocate resources elsewhere, potentially impacting the quality of the CMP service they provide.

API Availability

Considering API availability is vital, particularly for publishers aiming to seamlessly integrate data into their own Business Intelligence (BI) systems. Publishers seeking to consolidate insights and analytics from their ad monetization strategy can greatly benefit from a CMP that offers accessible APIs. This capability streamlines the process of extracting and analyzing data, enhancing the effectiveness of your decision-making processes.

Proof of Consent

When considering CMP options, it's wise to proactively inquire about the proof of consent they can provide in case regulatory authorities require verification. Having clarity on the types of evidence a CMP can provide in such situations ensures you're well-prepared to demonstrate compliance if the need arises. 

Benchmark Opt-In Rates

While comparing opt-in rates between providers might be challenging due to app-specific implementations, it can offer a ballpark estimate of what to anticipate post-implementation.

Other Features

There are several more aspects to think about, like how you handle retaining data and whether there are easy-to-access lists of TCF IAB vendors. These factors become really important when you're actually putting everything into action and implementing your chosen CMP solution.

Pricing Model

The importance of pricing is self-explanatory. Our research underscores significant variations in pricing models across different CMP solutions. Notably, Google consent management solutions and Quantcast are cost-free, whereas other CMPs might charge based on factors like the number of apps, Daily Active Users (DAU), Monthly Active Users (MAU), session count, or a combination thereof.

Additional CMP Implementation Factors 

Once you've chosen a CMP, there are a host of other factors to ponder and decisions to make. Here are some critical points to keep in mind:

  • Pop-Up Design: The exact layout and appearance of the consent pop-ups.
  • Button Configuration: Determining the necessary buttons according to TCF 2.2 guidelines. For instance, should you include "Accept all," "Manage options," or even a "Reject all" button on the initial user interface? Should an "x" button can be used?
  • Which Vendors to List: Many SDK vendors don't work with a TCF string. You'll need to establish how to handle them. Some partners do work with the TCF; for instance, Google, Ogury, Amazon Publisher Services (APS), Smaato, and Yahoo require TCF 2.2. This complexity increases when you consider the official list of TCF vendors, selecting the ones to include in your consent prompt.
  • Information in UI Layers: Defining the specific details to be presented in the first and second user interface layers and how to accommodate users who want to change their consent.
  • Integrating Legal Content: Determining whether to combine the current Terms of Service and Privacy Policy pop-ups with the CMP pop-up or keep them separate.
  • Pop-Up Sequence: Arranging the order in which these pop-ups appear, particularly when the App Tracking Transparency (ATT) message comes into play on iOS, aimed at avoiding Apple app review process issues.
  • Legal Team Involvement: Depending on your company's caution level, the involvement of legal teams might increase the complexity. They might seek to contribute to this process to ensure compliance with legal and regulatory requirements.

The Significance of CMP Implementation for Your Ad Monetization Strategy

While CMP implementation might seem less important for publishers earning only a small fraction of their revenue from ads, the absolute numbers can still warrant dedicated efforts toward a seamless CMP setup. Casual and hyper-casual game publishers should prioritize this aspect as it is essential to uphold ad revenues and ensure successful implementation.

The geographical distribution of a publisher's user base also shapes priorities. Publishers with fewer users in the EEA and UK regions might have different considerations than those with a larger presence. Furthermore, the current landscape indicates that while many SDK networks don't mandate TCF implementation, the implications of not implementing a CMP depend on the significance of Google ads within your inventory. However, this dynamic could shift if other major networks adopt similar practices.

Act Now to Seamlessly Implement CMPs

Time is of the essence. At GameBiz, we've committed extensive resources to assemble in-depth insights that empower our clients to tackle impending changes head-on. Our specialized CMP implementation services are ready and waiting, uniquely designed to align with publishers' distinct needs. As you navigate this evolving landscape, our support range includes:

  • Comprehensive Reports: Gain a deeper understanding with our detailed reports, delving into the broader GDPR context, global regulations, and TCF 2.2 requirements.
  • Strategic Analysis: Benefit from our thorough comparative analysis of Google-certified CMP solutions, ensuring you make the most informed choices.
  • Expert Consultations: Maximize your approach with our hourly consultations, providing tailored guidance for your specific circumstances.
  • Hands-On Assistance: Navigate the implementation journey seamlessly with our hands-on support, ensuring your chosen CMP solution is smoothly integrated.

Take action today to stay ahead of the curve and implement CMPs with confidence. Contact us now to transform how you manage user consent and optimize your ad monetization strategy.

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