Pay-or-Okay / Consent-or-Pay Models

Pay-or-okay (also called consent-or-pay) is a business model in which users can only choose between paid, advertising-free access and consenting to tracking or personalised advertising, with no third, tracking-free option offered free of charge. On 13 August 2025, in case W291 2272970-1, the Austrian Federal Administrative Court (BVwG) held the consent obtained by a provider of journalistic content to be invalid, because only a blanket overall consent covering several purposes had been collected instead of separate, granular consent; the court did not declare the pay-or-okay model as such unlawful. It expressly refused the referral to the CJEU suggested by the parties, holding that the proposed questions were not decisive for the case. For one operative part it allowed an appeal to the Administrative Court (VwGH) under Article 133(4) B-VG, so a final ruling by the highest courts is still outstanding. In the published text of the decision, all parties are anonymised throughout.

In practice

If you run a website in Austria or Germany and want to introduce a pay-or-okay model, or already use one, pay particular attention to the granularity of consent: that is exactly where consent failed in the BVwG case, not the paid option itself. Technically you need genuine granularity in the CMP, meaning separate toggles for analytics, marketing and personalisation rather than a single switch next to the paid option. Whether the model as such is permissible remains open for now: the BVwG refused a referral to the CJEU on that question but did allow an appeal to the VwGH. Before a broad rollout, therefore, arrange a legal review. Agencies should actively flag the risk to clients planning such a model and put alternatives such as contextual, non-personalised advertising on the table as a third option.

Matching service

Sources

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