Email tracking pixels: how to prepare your information campaigns before the July 14 deadline

News

10 Jun 2026 · Written by Baptiste Guerre

The clock is ticking. France's data protection authority (the CNIL) published its email tracking pixel recommendations on April 14, 2026. You have until July 14, 2026 to send an information email to your existing contact base. Miss that window, and you lose the benefit of the transitional regime which means re-collecting explicit pixel consent from your entire pre-April 14 database.

We already published a deep-dive on what the CNIL recommendations actually say: regulatory context, exempt use cases, what valid consent looks like, and a three-phase action plan. This article is the operational follow-through. Setup, segmentation, template choices, send planning: everything you need to execute before the deadline.

Context: what the CNIL requires, and why July 14 is non-negotiable

The CNIL recommendation, adopted March 12 and published April 14, 2026, regulates the use of tracking pixels in emails. It does not require blanket consent for every pixel only for specific purposes:

campaign performance measurement: open rate tracking to optimize sends, A/B test subject lines, adjust frequency or channel
engagement scoring and targeting: building audience segments based on email behavior for CRM personalization
cross-channel profiling: crossing open data with user interests to target profiles on other channels
fraud detection: analyzing unusual or automated open patterns

In practice: if you use email opens to drive campaign decisions, personalize sends, or feed CRM segments, you're in scope for consent.

For existing databases, the CNIL built in a transitional regime. You can keep using pixels on your existing contacts, provided you've informed them and given them the ability to object. One condition: send that information email before July 14, 2026, within three months of the Journal Officiel publication.

No email by July 14 means no transitional regime. You'd need to re-collect explicit pixel consent from every contact acquired before April 14.

Prerequisites: configure Batch before you do anything else

Before you touch a single campaign, you need to set up a few things in Batch.

Step 1: identify your pre-April 14 base

Find every profile whose email address was collected before April 14, 2026, without documented pixel consent. That's your transitional regime scope.

Once you have that list, create a segment or audience in Batch using those profiles, or tag them with a custom attribute (e.g. cnil_pixel_notice = true). You'll be able to target them directly in your information campaigns without rebuilding the selection later.

Step 2: flip those profiles to opted-in

Use the Batch Profiles API, Mass Update endpoint, to update the native attribute $email_open_tracking_consent to granted for each of those profiles.

Only do this if you're confident you'll send the information email before July 14. That's the condition that makes the transitional regime valid.

Step 3: activate the pixel flag in Batch settings

In your project settings, under Channels → Email, switch on tracking pixel management.

Once enabled, Batch will only insert a pixel in emails sent to profiles with granted consent. Profiles with denied or no value will not receive emails containing a pixel.

What this means in practice:

Your pre-April 14 base, now set to granted, continues to report email opens via pixel during the transition window.
Addresses collected since April 14, which default to empty or denied, get no pixel. That's the expected behavior if you haven't yet updated your sign-up form to request consent.

1. Segmentation: two campaigns, two different logics

Your send plan splits into two distinct campaigns: different audiences, different timelines, different goals.

Campaign 1: the information email to your pre-April 14 base

This one is urgent. It needs to go out before July 14, 2026. It's the email that qualifies your contact base for the transitional regime described in slides 29 and 30 of the CNIL webinar deck for publishers.

Before you segment, answer the scope question: do you need to reach your entire pre-April 14 base, or only the engaged segment you already contact regularly via newsletters? Focusing on active contacts reduces deliverability risk and keeps your send pressure under control.

Campaign 2: consent request for new contacts post-April 14

If you haven't updated your sign-up form to request pixel consent, you've likely been collecting addresses since April 14 without it. For these profiles, you can send a consent request email if you didn't get the opportunity to ask them at the point of email address collection.

2. Template: what each campaign needs

Template for Campaign 1 (existing base, pre-April 14)

Two formats are accepted by the CNIL:

A clear notice embedded in a standard marketing email, explaining pixel use and including an opt-out link.
A dedicated information email focused entirely on pixel tracking, with a clear opt-out mechanism.

The dedicated email is the safer, cleaner option. It removes any ambiguity about whether the information was actually communicated.

💡 Good to know: a native pixel consent withdrawal link is coming to Batch in the next few weeks. If you'd rather skip building your own opt-out mechanism, hold tight or ask your Batch CSM for the exact timeline.

Template for Campaign 2 (new contacts post-April 14)

This campaign has a different goal from Campaign 1. You're not informing contacts so they can object you're collecting explicit consent from people who haven't given it yet.

The flow works like this:

The email explains that you use tracking pixels in your emails for specific purposes (campaign performance, personalization, etc.) and invites the recipient to consent. The email itself contains no pixel.
The link in the email points to a dedicated landing page.
The landing page presents the purposes and includes an explicit acceptance button. Consent is only recorded when that button is clicked, not when the user lands on the page.

That last point matters. If consent were triggered by clicking the link in the email, security bots (which sometimes follow every link in an incoming email automatically, especially in B2B environments) would generate unintended consent records. The positive action on the page eliminates that risk.

Once the button is clicked, update the profile's $email_open_tracking_consent attribute to granted via the Batch API. Make sure you also store proof of the consent on your side, with all the relevant context.

3. Subdomain: don't reach for the transactional one

These campaigns will feel like transactional communications. Your first instinct might be to use your transactional sending subdomain.

That's a common mistake.

Your transactional subdomain is tuned for low-volume, high-priority mail: order confirmations, password resets, account alerts. Injecting a large batch of messages into it risks rate limiting reputation damage or delivery delays that put your critical emails at risk.

Use your newsletter subdomain instead. It's already built to handle volume, and its reputation is built on consistent bulk sends. If you're unsure which subdomain to use, check with your Batch CSM.

4. Send planning: warmup is not optional

Sending hundreds of thousands of emails in a single blast, even from a healthy subdomain, is a deliverability risk. Mailbox providers watch for unusual volume spikes.

Create a recurring send in Batch and enable the auto-warmup feature. This spreads volume across multiple days and protects your sender reputation. You still have time to do this right before July 14.

In your dashboard, go to Automations, then click "New Automation" → Email. In the timing section, enable Intelligent Warm-up and adjust the ramp-up pace.

⚠️ Watch out: if you wait until the last week of June to trigger your sends, there's no warmup window left. Plan early.

5. Proof of send: export before you archive

Compliance also means documentation. Once your information campaigns are sent, wait 24 hours after your automation ends enough time for all events to finalize in Batch.

Then run an export of your sends and keep it as proof in case the CNIL or your DPO asks for it. Each export includes the full event context: timestamp, identifier, email address, campaign ID, and more.

Batch provides a dedicated endpoint for exporting these events via the Profiles API (see documentation).

Checklist: three things to verify before you're done

Before you consider your pixel compliance complete, check these three boxes:

Updated sign-up form: does your sign-up form now explicitly request pixel tracking consent, with purposes clearly listed?
Footer withdrawal link: does every email containing a pixel include a link letting recipients withdraw consent on a frictionless page (no email re-entry required)?
Opt-out event export: are you exporting pixel consent withdrawal events via the Batch API and storing them in your own system?

References

Batch's deliverability and customer success team has been helping CRM teams navigate pixel compliance since the recommendations were published: technical setup, send planning, and mailbox provider relationships. Reach out if you want help building your roadmap before July 14.