New Changes Coming Soon: Google Requires Mobile App and Game Publishers to Collect TCF-Compliant User Consent for Ads

In an industry development that is expected to spark discussions, Google has announced that starting “later this year,” mobile app and game publishers will be required to collect user consent for displaying ads to users in the European Economic Area (EEA) and the United Kingdom (UK) that adhere to the transparency and consent framework (TCF).

Understanding the Basics

In a previous article, we discussed Google’s announcement on May 16, 2023, stating that they will mandate the collection of consent from users via a Google-certified Consent Management Platform (CMP) for those using Google AdMob, Google AdManager, or Google AdSense. While the initial announcement did not provide a specific deadline, Google has now set January 16, 2024, as the cutoff for publishers to comply with the new requirements.

However, despite the deadline, it seems that the industry is not in a rush to implement these changes. Many publishers are still in the exploration stage, and it wouldn’t be surprising if most of them delay the implementation until the last minute. This pattern is similar to previous industry novelties such as the introduction of Apple’s App Tracking Transparency (ATT) framework and the launch of the General Data Protection Regulation (GDPR).

Additionally, as the lucrative Q4 period approaches, publishers may be hesitant to make changes that could disrupt their ad monetization during the most profitable time of the year.

Additional Information from Google

In addition to the deadline, Google has released an official list of CMPs that they have certified. Publishers can find the list of certified CMPs here. At the moment, there are a total of 49 certified CMPs, but only 21 of them are available for mobile apps. Notably, Outfit7 is the only game publisher on the list that has an approved CMP from Google. Another game publisher, EasyBrain, has its CMP certified by IAB, but it is yet to receive Google’s approval.

While publishers have the option to create their own CMP, this approach is deemed impractical for most companies in the industry. Creating a CMP involves technical and legal efforts, as well as a significant amount of bureaucracy, as the solution needs to be certified by both IAB and Google. Unfortunately, there are no time estimates available for the certification process.

Choosing the Right CMP: Factors to Consider

At GameBiz Consulting, we conducted comprehensive research to identify the most suitable CMP solutions. We initiated three rounds of interviews with the initially certified 11 CMPs and shortlisted five solutions that met our criteria. Here are the factors we considered:

1. Support Availability: Implementation of a CMP is a complex task, and proper support from the CMP provider is crucial to avoid unintended damage to publisher’s ad revenues. Accessibility to support plays a vital role in choosing the right CMP.
2. Consent Pop-Up Customization: The ability to customize consent pop-ups is important as it can significantly impact opt-in rates, which, in turn, affects ad revenue. Out-of-the box solutions may not always be optimal for maximizing opt-ins.
3. AB Testing Availability: CMP platforms that offer built-in AB testing capabilities for different consent pop-up variations can help publishers maximize their opt-in rates.
4. Regulations Supported: Considering the location of a publisher’s users is essential when selecting a CMP. While Google currently requires TCF 2.2 compliance for EEA and UK users, publishers need to be prepared for potential future regulations worldwide.
5. TCF Version Supported: Ensuring that the chosen CMP has plans to update their TCF version to meet the 2.2 requirement by the deadline is crucial to avoid potential headaches in the future.
6. Integration Options: Different game engines require specific integration options (iOS, Android, React Native, Unity, Flutter, etc.), so publishers must consider compatibility with their development platforms.
7. Server Location: While data transfers to the US have been deemed adequate for now, some publishers may prefer CMPs with servers located within the EU to mitigate potential data transfer issues.
8. Experience with Game Publishers: Selecting a CMP with experience working with similar companies in the gaming industry ensures a greater understanding of specific needs and challenges.
9. CMP is a Core Product for the Provider: Opting for a CMP provider whose primary focus is their CMP product ensures greater commitment, attention, and dedication to the solution.
10. API Availability: Publishers seeking to integrate CMP data into their own business intelligence systems should prioritize CMPs that offer API access.
11. Proof of Consent: Publishers should request detailed explanations from CMP providers regarding the type of proof of consent they offer.