In this post, Gravito’s Lead Developer, Unnikrishnan Kurup, opens up the IAB’s TCF 2.2

Attention publishers! Stay in the loop about exciting changes to the TCF framework that will impact your advertising strategy. Stay ahead of the game with the inside scoop!

IAB’s (Interactive Advertising Bureau) Transparency and Consent Framework (TCF) has undergone and will continue to change to adapt to evolving privacy regulations and especially publishing industry needs. Through a consent management platform (CMP) like Gravito, publishers can give visitors a clear choice to allow specific data processing for targeted advertising and personalized content experience.

Planned Changes in the TCF Framework 2.2

The announced changes include enhancing user transparency, simplifying consent management, and ensuring interoperability with other industry initiatives. TCF version 2.2 aims to standardise further the information and choices provided to users over processing their data and how these choices should be captured, communicated, and respected. In addition, some changes are related to the Action Plan submitted to and validated by the Belgian Data Protection Authority (more information here).

Significant differences between TCF version 2.1 and 2.2

As we advance from September 2023, TCF version 2.2 is becoming effective and below are the significant differences between TCF version 2.1 and 2.2

  1. Removal of the legitimate interest legal basis for advertising & content personalisation:
    • within the scope of the TCF, Vendors will only be able to select consent as a sufficient legal basis for purposes 3, 4, 5 and 6 at the registration level.
  2. Improvements to the information provided to end-users: the purposes and features’ names and descriptions have changed. The legal text has been removed and replaced by user-friendly descriptions called Illustrations.
  3. Standardisation of additional information about Vendors: Vendors will be required to provide additional information about their data processing operations – so that this information can, in turn, be disclosed to end-users.
    • Categories of data collected
    • Retention periods on a per-purpose basis
    • Legitimate interest(s) at stake – where applicable
    • Support for multiple languages URL declaration
  4. Transparency over the number of Vendors: CMPs will be required to disclose the total number of Vendors seeking to establish a legal basis on the first layer of their UIs;
  5. Specific requirements to facilitate users’ withdrawal of consent: Publishers and CMPs will need to ensure that users can resurface the CMP UIs and withdraw consent easily. Vendors need to ensure they retrieve the TC String in real-time, where applicable.

Important dates to remember

30 June 2023: Vendors need to update their GVL registration with the new required information (as well as any other required information they failed to update previously)

31 July 2023: Vendors need to submit a TCF Compliance questionnaire

10 July 2023: CMPs must ensure they host their scripts on a domain other than subdomains

30 September 2023: As CMPs and Vendors are required to implement the new policies and specifications by the deadline, publishers are strongly encouraged to review their implementation of the TCF in line with the new policies.

If you are a publisher, then these are some of the dates that you should validate with your CMP provider and Vendors. Their readiness for the changes will be critical regarding your compliance which can directly or indirectly affect your ad revenues.

Gravito is here for you

The IAB and the Transparency and Consent Framework (TCF) are critical initiatives to foster transparency and protect user privacy in the digital advertising industry. As the digital landscape evolves, the TCF adapts to new regulations and industry needs, ensuring its relevance and effectiveness.  We at Gravito keep ourselves updated on the latest developments and try to help our publisher customers comply with the current standards and policies to make the most of their ad inventory.

Are you a publisher looking for a TCF-compliant CMP? Contact us.



Some new terms have been introduced.

Illustrations: The new user-friendly descriptions that replace the legal text aim to improve end-users’ understanding of each purpose further. The “illustrations” are indicative examples of operations covered by a given purpose, which can help end-users understand in practice how their data can be processed and why.

New Purpose 11: Purpose 11 (Use limited data to select content) is equivalent to the ad-related Purpose 2 (Use limited data to select advertising). This purpose is intended to cover processing activities such as selecting and delivering non-advertising content based on real-time data (e.g. Information about the page content or non-precise geolocation data) and controlling the frequency or order in which content is presented to a user. It does not cover creating or using profiles to select personalised content.

“Reject all” button:  The new TCF Policies do not require that CMPs provide a call to action for users to refuse consent from the first layer of their UIs. That being said, publishers should ensure they are fully aware of their local Data Protection Authority’s requirements and act accordingly.

Unnikrishnan Kurup

Unnikrishnan Kurup

Lead Developer

Unni is one of the co-founders of Gravito and heads the development of the technology behind Gravito. Gravito focuses on building a privacy-first web for the future helping publishers, and advertisers across Europe get ready for the cookie-less era.