Understanding Guidance on Email Tracking Pixels
This post is for informational purposes only. It is not legal advice and does not warrant your compliance. The Adobe Marketo Engage product capabilities described in this help article, configured and operated appropriately, support a compliant implementation. Each user is responsible for determining and complying with its obligations under applicable law.
Overview
On April 14, 2026, France’s data protection authority (CNIL) published a recommendation on the use of open tracking pixels in emails. Three days later, Italy’s independent data protection authority (“Garante”) published Provision No. 284 (the “Garante Provision”). Both guidances, while non-legally binding, clarify when consent is required and highlight the importance of proper consent practices for email pixel tracking. These policies could impact sending processes for any entity delivering emails to subscribers who fall under applicable EU privacy law.
As regulators continue to clarify guidance on tracking pixels and related issues, Adobe will continue to monitor updates and inform you of changing technical capabilities. Adobe’s documentation on email tracking pixels reflects current regulatory guidance. Adobe will continue to update documentation as needed to reflect relevant changes that may impact use of Marketo Engage as regulatory requirements evolve. Delays in updating materials do not constitute a failure on behalf of Adobe.
Marketo Engage offers controls that help you manage open tracking at the email level. Users are responsible for determining their own compliance obligations under applicable CNIL guidance and other laws.
What is an email tracking pixel
An email tracking pixel is a small transparent image (just 1x1 pixel in size) embedded in the HTML of an email. When a recipient’s email client loads the email images, the pixel pings a server that records data such as a timestamp, device type, email client, and sometimes an IP address for approximate location. That log is tied to the recipient’s record, allowing marketers to see whether an email is opened.
Guidance on consent tracking
Detailed steps are outlined for Marketo Engage users in this help article on Experience League.
Updates and support
For the latest updates, bookmark this post. If you have any questions, please post a comment below.
