The problem with Consent Management Platforms is they are unlawful by design

Every CMP I have looked at in fifteen years sets a cookie before the user has consented to anything. That is a direct breach of Article 5(3) of the ePrivacy Directive, restated by the CJEU in Planet49 (C-673/17), and reinforced by the Belgian decision against the IAB TCF. This piece explains, step by step, what a lawful consent flow actually looks like and why every cookie banner you have ever…