France’s cookie fines and influencer rules
France is the strictest market in Europe on cookies and advertising consent. On 1 September 2025 the CNIL fined Google €325 million for showing ads between Gmail users’ emails without consent and for cookies set at account creation, and fined SHEIN €150 million for cookies placed without consent. The 2023 influencer law applies to anyone promoting to a French audience. EU rules on political advertising and AI-generated content apply on top.
Executive findings
- 1
On 1 September 2025 the CNIL fined Google €325 million for displaying ads between Gmail users’ emails without consent and for placing cookies at account creation without valid consent.
Documented: official source. Scope: France; CNIL, as of . [1]
- 2
On 1 September 2025 the CNIL fined SHEIN’s Irish subsidiary €150 million for cookies placed without consent on shein.com.
Documented: official source. Scope: France; CNIL, as of . [2]
- 3
Law No. 2023-451 of 9 June 2023 regulates commercial influence, and applies to influencers addressing a French audience regardless of their location.
Secondary source. Scope: France; European Consumer Centre, as of . [4]
- 4
Regulation (EU) 2024/900 on political advertising has applied since 10 October 2025, including a ban on political ads from non-EU sponsors in the three months before an election or referendum.
Documented: official source. Scope: European Union; EUR-Lex summary, as of . [5]
- 5
AI Act transparency duties under Article 50 have applied since 2 August 2026; deepfakes and AI-generated public-interest text must be labelled unless a person has reviewed it and holds editorial responsibility.
Documented: official source. Scope: European Union; European Commission FAQ, as of . [7]
Method and limitations
- Question
- Which French enforcement actions and laws most affect advertisers in 2026?
- Written for
- Marketing leads and agencies buying media in France.
- Decision at stake
- What to change in France media plans, creative and data set-up in 2026.
- Sources
- CNIL decisions on Google and SHEIN, the European Commission’s Better Internet for Kids entry on Law No. 2023-451 and the European Consumer Centre France guide to influencer rules. EU sources: EUR-Lex summary of Regulation (EU) 2024/900, Meta’s announcement on EU political ads, and European Commission material on Article 50 of the AI Act.
- Period
- Official and legal sources as published and opened on 18 October 2026.
- Markets
- France, within the EU framework.
- Definitions
- Commercial influence: paid online promotion of goods, services or causes, as defined in Law No. 2023-451.
- Limitations
- We did not review every CNIL decision from 2025 and 2026.
- This is not legal or tax advice. Confirm obligations for your business with qualified counsel in the market.
CNIL enforcement on cookies and inbox ads
Documented: official source
The CNIL’s Google decision targets two practices: ads displayed between emails in Gmail, treated as direct marketing requiring consent, and cookies set during Google account creation without valid consent. The SHEIN decision concerns cookies placed on visitors’ devices as soon as they arrived on the site, before any choice.
The influencer law
Secondary source
France’s 2023 law defines commercial influencers as people who, for payment, promote goods, services or causes to the public online. Paid partnerships must be disclosed, some product categories cannot be promoted, and influencers living outside the EU who address a French audience must appoint a representative in the EU.
Political and social issue ads: EU rules and platform exits
Documented: official source
Regulation (EU) 2024/900 on the transparency and targeting of political advertising has applied since 10 October 2025 and covers France. It also bars political advertising from sponsors outside the EU in the three months before an election or referendum.
Meta responded by ending political, electoral and social issue ads in the EU. Its newsroom update says these ads stopped being delivered on 6 October 2025. Social issue ads are a wider category than election ads, so charities, campaign groups and brands running cause-led messages in France need a route that does not depend on Meta's political ad products.
AI-generated creative: labelling from 2 August 2026
Documented: official source
Article 50 of the EU AI Act has applied since 2 August 2026. Deepfakes, and AI-generated or AI-manipulated text published to inform the public on matters of public interest, must be labelled unless a person has reviewed the text and holds editorial responsibility. Providers of generative AI systems that were already on the market have until 2 December 2026 for the machine-readable marking duty.
The Commission published a voluntary Code of Practice on marking and labelling AI-generated content on 10 June 2026, including optional icons that deployers can use. For advertisers the practical step is a creative log: which assets were generated or altered with AI, who reviewed them, and where a label appears.
Where we see opportunity
FOCUSADS view
Strict consent enforcement favours advertisers with strong first-party relationships: loyalty programmes, logged-in retail media and consented email. Creators who follow the influencer law carefully are lower-risk partners, which gives compliant agencies and brands a stronger negotiating position.
How FOCUSADS applies this
FOCUSADS view
France plans run a policy screen per channel before budget is allocated: political and social issue messaging, regulated categories and AI-generated creative are checked first, and channels that cannot carry the message are removed with the reason shown.
How this connects to our method: How FOCUSADS screens channels by market
References
- Cookies and advertisements inserted between emails: Google fined 325 million euros by the CNIL, CNIL, accessed
- Cookies placed without consent: SHEIN fined 150 million euros by the CNIL, CNIL, accessed
- Law No. 2023-451 of 9 June 2023 aimed at regulating commercial influence, Better Internet for Kids (European Commission), accessed
- Influencers: obligations and responsibilities in Europe, European Consumer Centre France, accessed
- Summary of Regulation (EU) 2024/900 on the transparency and targeting of political advertising, EUR-Lex (European Union), accessed
- Ending political, electoral and social issue advertising in the EU in response to incoming European regulation, Meta Newsroom, accessed
- Transparency obligations under Article 50 of the AI Act, European Commission, Shaping Europe’s digital future, accessed
- Commission publishes Code of Practice on marking and labelling AI-generated content, European Commission press corner, accessed

