When Is the TCF Required? A Practical Guide to Version 2.3

The TCF (Transparency and Consent Framework) is now widely used across the digital advertising ecosystem. It helps ensure interoperability and a consistent interpretation of consent signals between a website and its various partners.

Because it is so ubiquitous, many organizations assume it is a mandatory step whenever personal data is collected. In reality, whether you need the TCF depends on a crucial distinction: the difference between buying advertising and displaying advertising on your own website.

A brand using Google Ads or other platforms to promote its products acts as an advertiser. On the other hand, a website that displays third-party ad placements—through solutions such as Google AdSense, Google Ad Manager, or AdMob—acts as a publisher.

The TCF is only mandatory in this second scenario: when your site serves ads from advertisers on its own pages. In that case, your CMP must also be part of the Google CMP Partner Program, as Axeptio’s Brands and Publishers solutions are.

In this new edition of Product Lab, we’re offering a step-by-step guide to help you fully understand the TCF, determine whether you actually need it, and choose the right consent solution for your setup. We’ll also introduce the latest version of the framework—TCF v2.3—which Axeptio already supports.

Why and When Should You Choose a TCF Cookie Banner?

As mentioned above, whether you need the TCF primarily depends on your business model, your technical architecture, and your website’s objectives. A site that displays third-party ads on its own pages (as most media websites and large content platforms like FIBA do) operates as a publisher. If those ads are targeted, delivered, or managed through Google AdSense, Google Ad Manager, or AdMob, then the TCF is required.

By contrast, a company that only uses Google Ads or other acquisition channels to promote its own products or services acts purely as an advertiser. It buys visibility but does not display third-party ads on its own site. This is the case for the vast majority of e-commerce, SaaS, and corporate websites today—and it does not require the use of the TCF.

So, is there any benefit in using the TCF outside of these cases?

Pascal Vautrin, Privacy Standards Expert at Axeptio explains: “Not necessarily. The TCF is an industry framework—not a universal requirement, even though it’s often treated that way. With Axeptio for Brands, you get more flexibility in how you design and customize your consent banner (and it’s also certified under the Google CMP Partner Program).” 

To help you clearly identify which solution best fits your web ecosystem, here’s a simple comparison table:

Comparison : Axeptio for Brands vs. TCF

So, the need for the TCF does not depend on how many partners you have, or whether they are listed in the Global Vendor List (GVL). The deciding factor is much simpler: Does your website display third-party ads through Google advertising solutions?

In Summary:

• The TCF is mandatory only for publishers serving ads via Google solutions.
• Axeptio for Brands is the right choice for all other scenarios.
• Banner flexibility: Axeptio offers much greater freedom (welcome text, purpose wording, video integration), while the TCF comes with stricter compliance requirements that limit customization.

What Are the Differences Between TCF Versions 2.2 and 2.3?

On February 28, 2026, all organizations implementing the TCF will be required to move from version 2.2 to version 2.3. This new version clarifies an ambiguity around the interaction between legitimate interest and special purposes. Lost already? Don’t worry—this change mostly affects technology partners and has little practical impact for publishers. Let’s walk through it step by step.

First, legitimate interest is one of the legal bases that a publisher’s partners may rely on. Here are the official TCF purposes (with their conventional numbers) that can be based on legitimate interest:

Users can object to these purposes through the cookie banner. However, the TCF also includes a separate category known as special purposes, which are:

For these special purposes, users cannot express an objection through CMPs, regardless of which CMP is used.

Pascal Vautrin, Privacy Standards Expert at Axeptio explains: “Let’s take the example of a partner that relies solely on legitimate interest to carry out its activities—something fairly common in areas like brand safety. A user may choose to object. In that case, the partner can no longer process data for those purposes. Until now, however, the partner also had no clear way of knowing whether it could still rely on special purposes, because it wasn’t always clear whether it was actually disclosed in the CMP’s vendor list.” 

TCF v2.3 resolves this ambiguity by making a previously optional segment of the consent string mandatory: the disclosed vendor section.

The disclosed vendor section is part of the TC_String that specifies whether a partner’s name is accessible in the vendor list presented by the cookie banner. This allows vendors to clearly determine whether they are permitted to rely on special purposes.

Axeptio Is Already Compatible with TCF v2.3

For companies using Axeptio for Publishers, transitioning to version 2.3 requires no action.

The solution will automatically move from version 2.2 to version 2.3, meaning Axeptio users are already aligned with the requirements of TCF v2.3, in accordance with the rollout timeline set by IAB Europe.