Last November, the EDPB issued draft guidelines on the technical scope of Art. 5(3) ePrivacy Directive (ePD) which regulates the use of cookies and similar tracking technologies. Our insight article at the time explored some of the key takeaways of this, and we noted the EDPB’s expansive interpretation that could have significant changes for the digital landscape as it captured not just cookies and trackers, but a much broader range of technologies and implementations (including those designed to be “cookieless”). This would mean that many of these approaches that are currently designed to operate without user consent could require such consent going forward.