Guidance Regarding Email Tracking Pixels
This post is for informational purposes only. It is not legal advice and does not warrant your compliance with applicable law. The Adobe Campaign product capabilities described below are building blocks that, configured and operated appropriately, may support a compliant implementation. Each customer is responsible for determining and complying with its obligations under applicable law.
Overview
On April 14, 2026, the Commission nationale de l’informatique et des libertés (CNIL), France’s data protection authority, published a recommendation on the use of tracking pixels within emails. Shortly after, Italy’s independent data protection authority (“Garante”) published Provision No. 284 (the “Garante Provision”) on April 17, 2026. Both guidance documents, while non-legally binding, clarify when consent is required and highlight the importance of proper consent practices for email pixel tracking. This policy could impact sending practices for any entity delivering emails to subscribers under applicable EU privacy law.
As regulators continue to clarify guidance on tracking pixels and related issues, Adobe will continue to monitor changes and inform customers of the technical capabilities of Adobe products that support email marketing, including Adobe Campaign. Adobe’s documentation on email tracking pixels reflects current regulatory guidance. Adobe will continue to update documentation as needed to reflect relevant changes that may impact use of Adobe’s CXO products as regulatory requirements evolve. Delays in updating materials do not constitute a failure on behalf of Adobe.
Adobe email marketing execution applications, including Adobe Journey Optimizer, Journey Optimizer B2B, Adobe Campaign, and Marketo Engage, provide controls that can help customers manage open tracking at the delivery or email level. Customers are responsible for determining their own compliance obligations under the applicable guidance and other laws, but these capabilities may support customer compliance efforts.
What is an email tracking pixel?
An email tracking pixel is a 1x1 transparent image embedded in the HTML of an email. When the recipient’s email client loads that image, the pixel pings a server that records data such as a timestamp, device type, email client and sometimes an IP address for approximate location. That log is then tied to a recipient’s record, allowing marketers to see whether an email is opened.
Customer Support
Customers seeking assistance implementing the changes described above may engage with their existing Adobe ecosystem. For technical questions about the Adobe capabilities referenced, contact your Customer Success Manager or technical account manager.
Adobe Campaign functionality related to email tracking
Customers may use Adobe Campaign’s native tracking, schema, and personalization mechanisms to address certain elements when configuring architecture to address the guidance surrounding email tracking pixels:
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Classification of the delivery. Extend
nms:deliverywith anemailTypeattribute (authentication, deliverability-only, transactional, marketing, public service, B2B prospecting). The classification drives which pixels are allowed without consent. -
Consent capture. Extend
nms:recipientwith a per-purpose consent structure carrying wording version, timestamp, capture source, and expiry. Extend sign-up forms and preference centers to collect pixel consent separately from the email opt-in. -
Pixel emission. Define one
NmsTracking_OpenFormulaper pixel purpose (authentication, deliverability, performance, profiling, fraud detection). A delivery typology rule selects which formulas to emit based on emailType and the recipient’s per-purpose consent. Personalization blocks encapsulate the logic so it does not live in individual creatives. -
Withdrawal. Add a Manage tracker preferences link to every email footer, distinct from the unsubscribe link. The link points to an
nms:webApplanding page authenticated throughidTracking; the recipient withdraws consent in one click, without re-entering their email address. A filter step added to the standard Tracking workflow prevents re-opens of previously delivered emails from being exploited after withdrawal. -
Proof of consent. Capture each consent event in an append-only log (a
pix:consentLogextension namespace, for example), with the wording version stored separately for retrievability after wording changes. Surface the log through the Adobe Campaign explorer and as a periodic export. -
Re-solicitation governance. A
lastPixelRefusalDatefield and a filtering typology rule prevent re-solicitation for at least six months after a refusal. A periodic workflow can help manage consent expiration. -
Reporting. Existing Adobe Campaign reporting continues to operate against the new fields (urlCategory, emailType, the consent flags) without code changes.
For more information regarding email tracking in Adobe email marketing execution applications see documentation here: