Precedent corpus / DPC (Ireland)
TikTok Technology Limited
DPC (Ireland) case IN-21-9-1, decided . EUR 345M.
We have not checked whether this decision was appealed. This is not a statement that no appeal exists.
No ConsentMark grade rests on this decision. It is published here because it is relevant enforcement, not because it bears on what a browser does before consent.
What the regulator decided
TikTok's public-by-default account settings and the Family Pairing feature failed to provide age-appropriate protection for users aged 13-17, breaching Articles 5(1)(a), 5(1)(c), 5(1)(f), 12(1), 13(1)(e), 24(1), 25(1) and 25(2) GDPR; consent flows for child users were not presented in an objective, neutral way.
Primary source
Regulator-owned URL. Quote this in legal briefs and academic citations.
https://www.dataprotection.ie/sites/default/files/uploads/2023-09/Inquiry%20into%20TikTok%20Technology%20Limited%20-%20September%202023%20EN.pdfArchived snapshot
Wayback Machine snapshot of the primary source. Use this when the regulator URL might be refactored or expire.
https://web.archive.org/web/20231017224852/https://www.dataprotection.ie/sites/default/files/uploads/2023-09/Inquiry%20into%20TikTok%20Technology%20Limited%20-%20September%202023%20EN.pdfConsentMark interpretation
Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.
Decision followed EDPB Binding Decision 2/2023 (Art. 65) on dispute resolution. The DPC's decisions index lists the case reference as IN-21-9-1 (not IN-21-9-7 as earlier note material had it). Cite alongside BD-02-2023 when the substantive issue is design patterns nudging child consent, not the cookie banner mechanics.
Verification trail
Checked against the primary source on 26th May 2026. Next review 26th November 2026.
Cite this case
@misc{consentmark-precedent-dpc-in-21-9-1,
author = {{ConsentMark}},
year = {2023},
title = {DPC (Ireland) IN-21-9-1 - TikTok Technology Limited},
howpublished = {\url{https://www.consentmark.com/precedent/dpc-in-21-9-1}},
note = {ConsentMark methodology v7.8.1}
}ConsentMark. (2023, September 1). DPC (Ireland) IN-21-9-1 - TikTok Technology Limited. Methodology v7.8.1. https://www.consentmark.com/precedent/dpc-in-21-9-1[DPC (Ireland) IN-21-9-1 - TikTok Technology Limited - ConsentMark](https://www.consentmark.com/precedent/dpc-in-21-9-1)DPC (Ireland) IN-21-9-1 - TikTok Technology Limited - ConsentMark, 2023-09-01, methodology v7.8.1, https://www.consentmark.com/precedent/dpc-in-21-9-1