Open Activity Tracking

Overview

The French and Italy Data Protection Authority (CNIL) published its final recommendation on 14 April 2026, clarifying that email tracking pixels used to measure recipient opens are subject to privacy requirements similar to cookies in many marketing scenarios. The recommendation explains when consent is required for email open tracking and encourages marketers to provide recipients with greater transparency and control over how user engagement data is collected.

To help marketers of France and Italy city [EU Nations] align with evolving CNIL privacy requirement, the platform provides a setting, “Open Activity Tracking” feature to control whether an email tracking invisible 1*1 pixel to be included in campaign and automation emails.

Customer Care → Realm Management → Edit Realm:

Who can do this?

Editing this option can only be done by Private Label Admins and can only be done to Child Realms. If you do not have access to the Edit Realm page, please contact Technical Support to have these settings updated.

How it Works:

1. The consent field

A new/existing user (profile) property records whether a recipient has consented to open tracking via pixel:

• Behavior:

  • If the open_tracking_pixel_opt_in_status value is null then consent is not collected, the tracking pixel will not be inserted.

  • If the open_tracking_pixel_opt_in_status value is no then consent is Opt-out for tracking pixel, the tracking pixel will not be inserted.

  • Only recipients with open_tracking_pixel_opt_in_status value as yes have the tracking pixel inserted.

The field name is published so you can begin loading your collected consent data against it now.

2. The location field

The platform determines whether a recipient falls under the requirement by reading the profile's country field, country. Only country is checked for the location decision, so it's important to capture the country field for all new subscribers, and backfill the existing subscribers.

Refer to Open Activity Tracking | How to Backfill the existing subscribers consent, country on how to backfill the country, consent of existing subscribers.

3. The suppression logic

1. Enable Based on recipient consent: When this option is selected, system checks whether the recipient is in a country with consent requirements [currently France, and Italy].

   1. If open_tracking_pixel_opt_in_status is explicitly ‘no' or 'null’ then open tracking pixel will not be inserted.

   2. If open_tracking_pixel_opt_in_status is explicitly ‘yes’ then the email is built normally and tracking continues.

   3. If the recipient’s country do not fall in-scope [France or Italy] then open pixel will inserted as per list behavior.
      

             Subscriber
                 │
                 ▼
            Is country known?
          /                    \\
        YES                  Insert Pixel [List selection]
         │                         
         ▼                         
   Is country France/Italy?           
      /                     \\                      
    YES                      NO                    
     │                        │                    
     ▼                        ▼      
  Check consent             InsertPixel    
         |                [List selection]     
         │
     ┌───┴───┐
    YES      NO/NUll
     │          │
     ▼          ▼
Insert Pixel    No Pixel insertion

In short: an explicit no always means "do not track," everywhere; a missing or null value is treated as "do not track." For recipients in a covered country [France & Italy], tracking also requires explicit yes.

How its managed in platform

A simple configuration options are available at the realm settings to enable email open activity tracking:

• Enable Based on recipient consent: Selection of this option will consider the consent per recipient and insert the open tracking pixel based on open_tracking_pixel_opt_in_status value in all campaigns sent out through the realm.

• Disable for all recipients: The platform excludes the email tracking pixel in all outgoing emails sent through the realm, regardless of the pixel's inclusion selection at the list level. As a result, email open activity will not be recorded or shown in all report pages.

• Use List Configuration (Default): The platform includes the email tracking pixel in all outgoing emails as per the selection in selected List. This is selected by default.

Applies To

This setting applies to:

Tasks → Deploy Wizard:

• Email Campaign

  • Normal.

  • A/B.

• Automation Campaigns.

• Automation 2.0 Campaigns.

Content → Template → Add/Edit template → Deploy Campaign.

Campaign/Automation Behavior

When Disable Open activity tracking is Disabled

The email includes:

• Open tracking pixel

• Open events

When Open activity tracking is set to

1. Enable based on recipient consent

The open tracking pixel will be inserted to recipients whose consent is “yes”, that fall under applicable country values, Open Activity Tracking | Coverage today and what's next
And other tracking methods, such as click tracking, continue to work if configured.

During Campaign/Automation creation,

• In the review tab – you’ll see an information note in red colored font, as referenced in the following screenshot.

2. Disable for all recipients

The email excludes:

• Open tracking pixel

• Open event collection

And Other tracking methods, such as click tracking, continue to work if configured.

During Campaign/Automation creation,

• In the Review tab - you’ll see an information note in red colored font, as referenced in the following screenshot.

3. Use List Configuration

Honors the list settings to include/exclude the open pixel/click tracking mechanisms.

Coverage today and what's next

• Countries in scope today: France & Italy.
  When a new country is added under CNIL regulatory, recipients there with ‘null’ or 'no' or 'yes' consent will be evaluated in the same way.

• Applicable Country values:

  • For France:

• • For Italy:

How to Backfill the existing subscribers consent, country

1. Configure the below additional custom fields in the realm, Subscribers → Custom Fields to update the subscriber tables.

   1. open_tracking_pixel_opt_in_status

   2. open_tracking_pixel_opt_in_date

2. Navigate to Customer care → Realm Management → Edit Realm → Open activity tracking.

3. Choose “Enable based on recipient consent”.

4. Additional option “Update existing subscriber’s country value and consent status“ open-up, as referenced in below screenshot.
   

   

5. Choose either of the options:

   1. One-time consent initialization: This is a “one-click” quick way to update the consent status, which allows to update the consent status of all France and Italy subscribers. Choose any one from the 3 options.

      1. Initialize all existing France and Italy subscribers as Opted-In.

      2. Initialize all existing France and Italy subscribers as Opted-Out.

      3. Leave consent as Unknown.
         

         

   2. Update Country & Consent using batch file: This option is to import a batch file with the subscribers data with outlined header format, where the country field, consent status can be updated.

      • Acceptable header formats:

        • email,open_tracking_pixel_opt_in_status,country

        • email,fname,open_tracking_pixel_opt_in_status,country

        • customer_key,open_tracking_pixel_opt_in_status,country

        • Note: email may be replaced with email_md5 in either of header formats.

      • Choose the data format, whether a comma/tab/pipe/caret/colon/semicolon separated values.

      • Choose whether the first record must contain field headers.

6. Click on “Update” to update the subscribers data and realm settings.

Once the upload is complete, the

Important Notes

• The setting applies to emails sent after activation and does not change past campaign data.

• Enabling or disabling this option affects only email open tracking, not delivery.

• Click tracking and other configured tracking capabilities remain unaffected unless configured separately.

• Marketers must configure this setting to comply with CNIL privacy laws and internal policies, of EU nation, especially for France from 2026-07-14 and Italy from 2026-10-28.

Frequently Asked Questions

1. Why did my open rate decrease?

Open tracking is performed only for recipients who are eligible under your configured compliance rules. This may reduce the number of recorded opens.

2. Does this affect click tracking?

No. Click tracking is independent of email open tracking and continues to function according to your account configuration and applicable privacy requirements.

3. Can I disable this feature?

Yes. Super User and Private Label Admin can manage open tracking pixel insertion based on organizational requirements, unless it has been enforced by your organization's compliance policy.

4. Are historical campaigns affected?

No. The feature applies only to emails sent after it has been enabled.

5. Which reports are affected?

Reports that rely on email open tracking, including:

• Open Rate

• Unique Opens

Regulatory Timeline

• 2026-07-14 – Law is live for France country.

• 2026-10-28- Law will be live for Italy country.

References:

• CNIL – Recommendation on Tracking Pixels in Emails (Published: 14 April 2026)

  • https://www.cnil.fr/sites/default/files/2026-05/recommandation_tracking_pixels_emails.pdf