CNIL & Web Analytics Without Consent: What You Absolutely Need to Know
TL;DR
The French data authority CNIL allows web analytics without user consent only if very strict rules are met: purpose limited to audience measurement, no cross-site tracking, anonymized IPs, cookie lifetime ≤13 months, retention ≤25 months, no data reuse, user opt-out, and compliant transfers.
Sealmetrics was built from the ground up to respect all these CNIL guidelines — meaning you can measure traffic and conversions in France legally, without losing data to consent banners.
Why this matters (and why you’re seeing this post)
Marketers, site operators, and analytics users often wonder:
- “Can I measure site traffic in France without showing a cookie banner?”
- “How strict are CNIL’s rules on analytics without consent?”
- “Which analytics tools actually comply with CNIL’s exemption program?”
Those are exactly the kinds of questions we’re answering here. If you do business in France — or worry about what the French regulator permits — this is essential reading. And yes: Sealmetrics already aligns with the CNIL’s conditions (I’ll show you how).
What does CNIL allow (and not) — the “consent exemption” for analytics
The principle: analytics cookies can be exempt — under tight conditions
In its guidelines, the CNIL provides a limited exemption to the consent requirement for analytics cookies, but only if specific criteria are met.
In other words: not all analytics tools qualify. The exemption only applies when the data collected is strictly necessary, anonymous, and used solely to measure audience for the publisher’s site/app. [link]
Key CNIL requirements for the exemption
Here is a condensed and more user-friendly version of the CNIL’s core conditions:
Requirement |
What it means |
Source / note |
|---|---|---|
Limited purpose |
Only measurement of audience, performance, navigation problems, technical optimization. No use for advertising, profiling, cohorting, etc. |
|
No cross-site tracking / no third-party identifiers |
The analytics tool must not use identifiers shared across domains. All cookies must be first-party. |
|
IP anonymization / truncation |
The last byte (or more) of the IP address must be masked. |
|
Cookie lifetime ≤ 13 months |
And it must not automatically reset or renew on each visit. |
|
Data retention ≤ 25 months |
Raw data can’t be kept forever; it must be periodically purged or aggregated. |
|
No mixing / combination with other systems |
Analytics data must remain separate from CRM, logs, profiles, etc. |
|
Segregation between clients (if provider serves many sites) |
The provider must ensure no data sharing or identification across customer sites. |
|
Right to opt-out & user information |
Users must be informed that measurement is happening, and have the ability to opt-out (i.e. “do not count me”). |
|
No reuse for provider’s own purposes |
The analytics provider cannot reuse that data (e.g. for their own marketing, improving models) without separate consent. |
|
Transfers & proxy / server architecture |
If data goes outside the EU, proper safeguards, or a proxy architecture must be used to avoid direct terminal → external server contact. |
If any one of these conditions is broken, the exemption no longer applies and user consent is required.
Typical FAQs (and straightforward answers)
Q: So does this mean I never need a cookie banner in France?
A: Not always. Only the measurement part of analytics that is configured to follow all the CNIL criteria can be exempt. If you want features like user identifiers, profiles, campaign attribution, eCommerce tracking, those will require consent.
Q: What about Google Analytics?
A: As of now, Google Analytics (standard or 360) is unlikely to fit within these CNIL exemptions, because it is built to integrate with advertising ecosystems and share data.
Q: Can my analytics provider claim “CNIL-exempt” status?
A: The CNIL itself offers an auto-evaluation tool (July 2025) that providers can use to check whether their configuration could be exempt.
Also, CNIL explicitly states: even if a provider claims the exemption, you (as site owner) must demand proof/documentation of compliance.
👉 CNIL – Cookies & tracers rules
Q: What about data transfer outside Europe?
A: Exemption doesn’t absolve compliance with GDPR and cross-border rules. If tools send data outside the EEA, they must use mechanisms (e.g. adequacy, standard contractual clauses) or proxy the data so that it doesn’t leak re-identifiable info.
👉 CNIL – Audience measurement & data transfers
Analytics tools that claim or are aligned with CNIL exemption (and where Sealmetrics fits)
Below are some analytics platforms known to offer or publicize configurations that align with CNIL’s exemption (when correctly configured). Sealmetrics is built with all those technical guardrails by default — so we belong in this list.
Analytics tools that align with CNIL exemption
|
Tool / Provider |
Notes / how they align |
|---|---|
|
Piwik PRO |
CNIL added Piwik PRO Analytics Suite to the list of analytics platforms usable without consent, if correctly configured. 👉 Piwik PRO on CNIL exemption |
|
Piano Analytics / AT Internet |
They provide a “consent exemption” mode under their analytics product. 👉 Piano Analytics – Consent exemption mode |
|
Wysistat |
They advertise being exempt under CNIL: cookies limited to 13 months, anonymized IP, no fingerprinting, no reuse, opt-out support. 👉 Wysistat – Exemption CNIL |
|
Contentsquare |
They offer an “Exemption Mode” for French clients to comply with CNIL guidelines. 👉 Contentsquare – Audience measurement exemption |
|
Sealmetrics |
(Yes, us) We designed Sealmetrics from day one to comply fully with the CNIL exemption requirements. All features are built around the strictest guardrails: minimal data, anonymization, opt-out, no cross-site tracking, separation of data, limited retention, and full documentation. 👉 Sealmetrics – Consentless analytics |
What you should do now (if you’re operating in or targeting France)
- Review your analytics stack — does it meet all the CNIL criteria above?
- Ask your vendor to provide documentation of their auto-evaluation vs. CNIL requirements.
- Consider switching or upgrading to a tool that inherently supports exemption mode (like Sealmetrics).
- Document your compliance in your privacy policy and cookie policy, offering users a clear opt-out mechanism.
- Monitor changes — CNIL and data regulation evolve; stay aware of new guidelines, especially in 2026+.
The CNIL’s “consent exemption” is a niche but powerful route: it lets you collect audience data in France without blocking users behind consent banners, if and only if your analytics tool meets strict technical/contractual requirements.
Sealmetrics is purpose-built to satisfy those constraints. If you’re curious how it works in your setup or want us to audit your current analytics stack vs. the CNIL guidelines, book a demo.
Let’s make analytics frictionless and lawful.