Update on the Belgian ruling on IAB Europe’s TCF

Julie Rubash, Chief Privacy Counsel
September 8, 2022
TCF update

On Wednesday, September 7, 2022, the Belgian Market Court issued a new judgment regarding the IAB Europe’s appeal of the Belgian data protection authority’s decision on the legality of the TCF. 

They’ve referred legal questions to the Court of Justice of the European Union (CJEU) for a preliminary ruling. In summary, these are:

  • Does the TC String constitute personal data, especially if combined with an IP address?
  • Is the IAB Europe considered to be a joint data controller if it does not have access to the personal data processed by the publishers and vendors utilizing the TCF?

The IAB Europe’s appeal of the decision is suspended pending the CJEU’s response to these legal questions.

The timing for the CJEU’s response to the Market Court’s questions is also unknown, but the IAB Europe has said that it does not expect a final decision “until 2023 or even 2024.”

Update: On 11th January 2023, the Belgian DPA approved the IAB Europe’s action plan submitted in April 2022. The IAB must implement the action plan within six months. Refer to our FAQ for further information.


  • Belgian DPA press release on preliminary questions to the CJEU (7 Sept 2022)
  • Text of the Belgian Market Court judgment (7 Sept 2022)
  • IAB Europe statement on the Belgian Market Court referral of TCF ruling to CJEU (7 Sept 2022)
  • Sourcepoint FAQ on the Belgian DPA’s decision on the IAB’s TCF (Updated 11 January 2023)

Latest Blog Posts

Vermont Data Privacy Bill Is Vetoed

June 17, 2024

Vermont Governor announced his veto of a bill that...

You Are Who You Work With: Cookie Consent and Data Privacy

June 11, 2024

Who you work with for consent management and data...

Texas AG Prepares for “Aggressive Enforcement” of Privacy Laws

June 10, 2024

Texas Attorney General announced a data privacy and security...

Latest White Papers

Benchmark Report: US Privacy Compliance

August 19, 2022

The current state of publisher compliance with CCPA, and...

Ebook: A Publisher’s Guide to Vendor List Curation

December 16, 2021

How to review your vendor list to mitigate compliance...

Keep in touch

Sign up for our newsletter to keep up with privacy news for adtech and martech,
plus occasional company news.

Let's explore what we can do together.

We'll be in touch within 48 hours

[contact-form-7 id="593" title="Schedule a Demo"]