Recommendations 2/2025 on the legal basis for requiring the creation of user accounts on e-commerce websites

The European Data Protection Board welcomes comments on the Recommendations 2/2025 on the legal basis for requiring the creation of user accounts on e-commerce websites.
Such comments should be sent 12th February 2026 at the latest using the provided form.

Please note that, by submitting your comments, you acknowledge that your comments will be published on the EDPB website.

The EDPB Secretariat staff screens all replies provided before publication (only for the purpose of blocking unauthorised submissions, such as spam), after which the replies are made available to the public directly on the EDPB public consultations’ page. Unauthorised submissions are immediately deleted. The attached files are not altered in any way by the EDPB.

Please note that your contribution may be subject to a request for access to documents under Regulation 1049/2001 on public access to European Parliament, Council and Commission documents. In this case the request will be assessed against the conditions set out in the Regulation and in accordance with applicable data protection rules.

All legal details can be found in our Specific Privacy Statement (SPS).