The Italian Data Protection Authority recalled that the six-month period granted by the Guidelines of 17 April 2026, published in the Official Gazette on 29 April, expires on 29 October 2026. The October recall makes it urgent for companies, mass sending platforms and newsletter managers who use remote images or equivalent techniques to detect recipients' openings and behaviour to adapt.

According to the Authority, the pixel can fall under art. 122 of the Privacy Code and, for tracking purposes, requires prior, free, specific and informed consent, except for the limited technical, security or institutional and service communication hypotheses contemplated by the Guidelines. The information must explain what is measured, for what purposes and with which subjects; the recipient must be able to withdraw consent easily and in a granular way. The GDPR discipline continues to apply to roles, accountability, minimization and privacy by design.

In practice, it is necessary to register the pixels embedded in the templates, the settings of the marketing providers  and the openings recorded also on behalf of third parties; disable tracking until the valid choice; separate the revocation of tracking from the management of communications, when appropriate; update the information, register and contractual agreements.

Finally, it should be remembered that the Authority has indicated the verification of the Guidelines among the areas of inspection in the Plan for the second half of 2026.