---
title: "Netherlands — AdTech &amp; Commercial Privacy | Data Protection Monitor"
canonical: https://dataprotection.gi/jurisdictions/netherlands/adtech-and-commercial-privacy/
source_html: /jurisdictions/netherlands/adtech-and-commercial-privacy/index.html
description: "Netherlands — AdTech &amp; Commercial Privacy: adtech_and_commercial_privacy AdTech &amp;amp; Commercial Privacy 6 sub-modules 2 claims Amber &amp;#9662; # Cookie and direct-marketing rules are well documented; dark-pattern, opt-out-signal, clea"
generated_at: 2026-10-25T04:46:50Z
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generator: "fe-fleet/md-twin@1.0"
---
# Netherlands — AdTech &amp; Commercial Privacy | Data Protection Monitor

### D7AdTech & Commercial Privacy6 sub-modules2 claimsAmber&#9662;#

Cookie and direct-marketing rules are well documented; dark-pattern, opt-out-signal, clean-room and cross-context-advertising sub-modules lack NL-specific findings.

Primary framework Telecommunicatiewet (ePrivacy transposition); GDPR

Supervisory authority [Autoriteit Persoonsgegevens (AP)](https://autoriteitpersoonsgegevens.nl/)

Traffic-light rationale &mdash; Amber Cookie and direct-marketing rules are well documented; dark-pattern, opt-out-signal, clean-room and cross-context-advertising sub-modules lack NL-specific findings.

#### Sub-modules (6)

#### Cookies And TrackersGreen

Prior informed consent is required before storing or accessing information on a user&#x27;s device, applying technology-neutrally to any tracking technology, not solely cookies.

Claims (1):

- The confidentiality-of-terminal-equipment rule transposed into Dutch law from the ePrivacy Directive is technology-neutral, meaning user consent (or an applicable exception) is required not only for cookies but for any tracking technology accessing or storing information on a device.

#### Dark PatternsRed

No NL-specific dark-pattern prohibition distinct from EU-level DSA/GDPR interplay guidelines was surfaced.

Absence provenance: unavailable . Searched: Netherlands dark patterns cookie consent AP guidance.

#### Opt Out SignalsRed

No NL-specific recognition of browser-level opt-out signals (e.g., Global Privacy Control) was identified.

Absence provenance: unavailable . Searched: Netherlands Global Privacy Control AP recognition.

#### Clean Rooms And DcrRed

No NL-specific data clean-room regulatory framework was identified.

Absence provenance: unavailable . Searched: Netherlands data clean room regulation AP.

#### Cross Context AdvertisingAmber

No NL-specific &#x27;sale&#x27;/&#x27;share&#x27; construct analogous to US state law exists; cross-context advertising is governed by GDPR consent/legitimate-interest analysis and the ePrivacy cookie rule.

Absence provenance: unavailable . Searched: Netherlands cross-context advertising GDPR ePrivacy.

#### Direct MarketingGreen

Telemarketing to natural persons requires opt-in consent since 1 July 2021; the do-not-call register was discontinued.

Claims (1):

- Prior to a 1 July 2021 amendment to the Telecommunications Act, telemarketing calls to natural persons operated on an opt-out basis; this was replaced with an opt-in consent requirement and the do-not-call register is no longer used.

Category narrative 64 words

The Telecommunicatiewet&#x27;s cookie-consent rule requires prior, informed consent before storing or accessing information on a user&#x27;s terminal equipment, applying technology-neutrally to all tracking technologies, not only cookies. Since 1 July 2021, telemarketing to natural persons requires opt-in consent, replacing the prior opt-out/do-not-call regime. NL-specific findings on dark patterns, opt-out signals, clean rooms, and cross-context advertising were not surfaced beyond general EU-level DSA/GDPR interplay guidance.

Periodic update &middot; new data 2026-10-11

#### AdTech & Commercial Privacy

Since 1 July 2026, businesses may no longer call consumers for telemarketing purposes without consent under the amended Telecommunicatiewet, even where the consumer is, or has been, a customer of that business. This closes the telephone-channel soft opt-in that previously permitted calls to existing customers without separate consent. The amendment is limited in scope: it applies to telephone calls only and does not alter the separate existing-customer soft opt-in for email and SMS marketing preserved under article 11.7(4) of the Telecommunicatiewet. The amendment also carves out charities, lotteries that donate proceeds to charity, and periodical publishers from the tightened consent requirement.

This is the one confirmed in-force change to the Dutch direct-marketing framework this cycle; no cookie-consent-specific or broader adtech development was independently re-verified in this window.

#### Outlook

Businesses that previously relied on the existing-customer telephone soft opt-in will need to have obtained affirmative consent before any telemarketing call made since 1 July 2026; the practical enforcement pattern around this change, including whether the Autoriteit Persoonsgegevens or another body brings early test cases, is the item to watch.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Evidence 2

Sources and claims (2)
- Confirmed[EDPB](https://www.edpb.europa.eu/sites/default/files/files/file1/edpb_statement_on_eprivacy_nl.pdf) &mdash; The confidentiality-of-terminal-equipment rule transposed into Dutch law from the ePrivacy Directive is technology-neutral, meaning user consent (or an applicable exception) is required not only for cookies but for any tracking technology accessing or storing information on a device.observed 2026-08-03
- Confirmed[DataGuidance](https://www.dataguidance.com/opinion/netherlands-amendments-made-dutch-telecommunication) &mdash; Prior to a 1 July 2021 amendment to the Telecommunications Act, telemarketing calls to natural persons operated on an opt-out basis; this was replaced with an opt-in consent requirement and the do-not-call register is no longer used.observed 2026-08-03
