February 26, 2026
The Israeli Privacy Protection Authority (PPA) has finalized its legal interpretation on consent, paving the way for implied consent banners, including beyond cookies. This opinion will guide enforcement and supervision under the Protection of Privacy Law (PPL).
Some points are framed as recommendations (e.g., responding favorably to consent withdrawal requests), which are not mandatory but will be viewed positively.
Key Takeaways for Organizations
✅ Privacy Notice: Ensure all legal requirements are met; include enhanced disclosures (e.g., biometric data, AI processing).
✅ Interface (Recommendation): Make notices highly accessible by using visuals, pop-ups, layered information, and separate consent for unusual processing.
✅ Interface (Strict Opinion): Avoid dark patterns when obtaining consent.
✅ Consent Banners: Use prominent banners for implied consent, not limited to cookies.
✅ Take-It-or-Leave-It Consent: Only lawful if a genuine alternative exists.
✅ Evidence: Be ready to demonstrate consent was informed and freely given, especially in cases of unequal bargaining power.
✅ Enforcement: Expect stricter oversight, administrative fines, and database registration scrutiny.
The opinion demonstrates a demanding stance toward securing and demonstrating consent. As there are no other lawful grounds of processing under the PPL (except for statutory authority), and the PPA has substantial enforcement powers, this opinion requires meticulous attention.
Read the full Opinion here (Hebrew)
For tailored guidance on implementing compliant consent mechanisms under Israeli law, our team advises technology companies, employers, digital platforms, and multinational organizations navigating complex regulatory environments.
