This post was written in January 2017, when it appeared the reform was heading towards a tidy conclusion. That did not turn out to be the case. As of November 2019 the reform of the ePrivacy Directive is still in draft and has not been finalised.
The changes that have occured in the draft versions between January 2017 and now have changed the shape of what the legislation is likely to take, to the point where I have taken the decision to delete the post I originally wrote below, as it was essentially useless. You should not take anything from the previous version of this post as definitive policy or legal advice (nor should you ever).
Please continue to follow this blog for news on the finalisation of the reform, which I will post when there is anything worth posting about.
UK residents should also follow my side blog, afterbrexit.tech, for details on the eventual regulation’s implementation into UK legislation.
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