Europe’s data watchdogs already have all the evidence they need to reject Pay or OK

In July 2025, ICCL Enforce submitted a submission to each of Europe’s data protection authorities and the European Data Protection Board that summarises relevant case law and enforcement decisions, which show that consent to RTB can not be a lawful condition of access to a website or an app. 

European data protection watchdogs are deliberating over whether websites and apps should be allowed to make access conditional on people agreeing to the data free-for-all in online advertising, including notorious Real-Time Bidding (RTB). This is known as the “consent or pay” debate. 

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