Paris Lawyers Share Takeaways from EDPB Recommendations

Article  |  February 18, 2026

Law360

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In an in-depth article for Law360, partners Vera Lukic and Ahmed Baladi (Co-Chair of our Privacy, Cybersecurity, and Data Innovation Practice Group) and associate Hermine Hubert share their key takeaways from the European Data Protection Board’s (EDPB’s) recommendations addressing the legal basis for requiring users to create accounts on e-commerce websites.

“This guidance marks a significant intervention by the EDPB into a commercial practice that affects controllers in the e-commerce sector operating within the European Economic Area or otherwise subject to the General Data Protection Regulation,” they write.

The article examines the scope and practical implications of the EDPB’s recommendations, analyzing when mandatory account creation may — and, more often, may not — be justified under the GDPR according to the EDPB. It also highlights the risks that regulators have identified with forced account creation and concludes with actionable takeaways.