AWIN’s new tracking & compliance requirements: What businesses need to know

Affiliate marketing is a vital channel for many businesses, but new changes in cookie consent regulations and tracking requirements mean that brands must review their tracking setup to ensure they remain compliant and importantly, to ensure seamless performance attribution.

Recently, the Information Commissioner’s Office (ICO) clarified that most affiliate tracking cookies require explicit user consent, unless specific conditions are met. As a result, AWIN is introducing a whitelist-based tracking system and a new conversion protection initiative (CPI) set to roll out on 7^th April 2025.

What’s changing?

1. Cookie consent & compliance

Under Privacy and Electronic Communications Regulations (PECR), cookies used for tracking typically require explicit user consent unless they are deemed strictly necessary. The ICO has stated that some affiliate tracking cookies may qualify as necessary – but only if:

• The user signs up for an account with the affiliate website.
• The terms & conditions clearly state that tracking is required for cashback or rewards.

For the majority of affiliate activity, where users don’t create an account before clicking an affiliate link, consent is still mandatory before cookies can be placed.

2. AWIN’s whitelist-based tracking approach

To align with these regulations while maintaining accurate tracking, AWIN is introducing a whitelist system:

• When a user lands on a website through an affiliate link, the tracking ID in the URL is checked against a pre-approved whitelist of valid affiliate partners.
• If the affiliate ID is on the whitelist, AWIN’s cookies can be placed automatically.
• If the affiliate ID is not on the whitelist, the user must provide explicit consent before any tracking takes place.

While this helps ensure compliance, businesses must carefully manage their whitelist implementation to avoid tracking disruptions.

3. AWIN’s conversion protection initiative (CPI) – effective 7^th April 2025

AWIN is also launching the conversion protection initiative (CPI) to address untracked affiliate sales caused by cookie restrictions, ad blockers, and cross-device behaviour.

Key elements of CPI:

• Server-to-server (S2S) tracking is strongly recommended to ensure accurate conversion attribution without relying on browser-based cookies.
• Businesses that don’t implement S2S tracking will have estimated sales automatically added to their programs using AWIN’s probabilistic tracking model.
• This could result in higher commission costs for businesses, as they may end up paying for previously untracked conversions.

For many businesses, this will feel like an additional cost, but in reality, it reflects sales that were always happening but not attributed due to tracking limitations. Other affiliate networks will likely implement similar models over time.

What should businesses do next?

With the 7^th April deadline approaching, businesses should:

• Review their current affiliate tracking setup to ensure compliance with PECR & AWIN’s policies.
• Check if they’ve been contacted by AWIN regarding CPI and confirm what tracking upgrades are needed.
• Implement S2S tracking to avoid relying on AWIN’s probabilistic tracking model.
• Test the AWIN whitelist approach to confirm correct implementation, especially for businesses using custom tracking solutions.

At Wolfenden, we’re already working with our clients to navigate these changes and ensure compliance. Our team can collaborate with your internal data teams to review and optimise your tracking setup, ensuring accurate attribution while staying compliant with evolving regulations.

If you need some support, get in touch with our team today.