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Orange: withdrawal had to stop cookie access, not just update the banner

CNIL fined Orange EUR 50 million for inbox advertising and cookies read after withdrawal. The cookie injunction was later closed following remediation.

CNIL · French Data Protection Act Article 82; French CPCE Article L.34-5 · Decision: 14 November 2024

The problem

A saved withdrawal choice is insufficient if subsequent requests still read advertising cookies.

€50mEUR administrative fine in cited decision; not confirmed paid

Regulator or court
CNIL
Jurisdiction
France
Framework
French Data Protection Act Article 82; French CPCE Article L.34-5
Decision
Procedural status
Fine imposed; cookie injunction closed on 11 September 2025

Cookies before choice or after refusal · Failed opt-out controls

Case record

Authority
CNIL
Jurisdiction
France
Law
French Data Protection Act Article 82; French CPCE Article L.34-5
Decision date
14 November 2024
Recorded fine
EUR 50,000,000
Procedural status
Fine imposed; cookie injunction closed on 11 September 2025
Source review
19 October 2026

What the authority found

CNIL’s follow-up recounts two findings: advertisements presented among inbox emails without the required consent, and continued cookie reads on orange.fr after withdrawal. CNIL follow-up closing the injunction.

Orange subsequently demonstrated removal of relevant first-party cookies and prevention of further third-party read/write operations on its site by stopping new third-party requests. Authority notice on EDPB.

Outcome and limits

The recorded fine is EUR 50,000,000. On 11 September 2025 CNIL closed the cookie injunction and declined to enforce the conditional daily penalty. Closure of that injunction is not described here as cancellation of the original fine. CNIL follow-up closing the injunction.

Checks for your own systems

These are implementation checks suggested by Inth, not additional findings about the company.

  • Test after withdrawal, then navigate and reload; inspect requests as well as the stored preference.
  • Review cleanup of first-party cookies and controls that prevent further requests to third-party domains.
  • Document the boundary between controls on your own site and actions only the external cookie owner can take.

How Inth helps

Website audit can record observable requests and consent state. Inth Consent gates optional integrations under the configured opt-in policy and records visitor choices.

Do not assume a banner deletes every third-party cookie or controls tracking on another website. Vendor configuration and withdrawal behaviour still need testing.

Sources and limits

Source review: 19 October 2026. This is a dated account of the cited authority decision. A recorded fine is not a confirmed payment. Later procedural developments are stated only where the linked record establishes them. Inth wrote the implementation checks; they do not establish legal compliance or replace legal advice.