We’d rather you heard the cost from us than from your agency three months after you certify. So here it is first.
The cost: the platforms lose their signal
The ad platforms’ automated bidding learns from what you tell them about each sale. Google describes Smart Bidding as bidding strategies that “use Google AI to optimize for conversions or conversion value in every auction”. The four strategies are Target CPA, Target ROAS, Maximise conversions and Maximise conversion value. Google says Smart Bidding needs conversion tracking switched on before you use it. For value-based bidding, you define the value to maximise, such as revenue or margin, “when you set up conversion tracking”. The system then sets bids in each auction to win the most valuable conversions it can for your budget.
Performance Max works the same way. Google’s own guide tells advertisers that “conversion goals and actions will directly guide Google AI”. Its bid strategies are Maximise conversions and Maximise conversion value, with optional CPA or ROAS targets.
Meta is no different. Its ROAS-based bid strategy needs you to pass “transaction values to our platform”. Those values arrive through the Meta pixel, app events or the Conversions API. Advantage+ sales campaigns bring together Meta’s automated budget, audience and placement settings, and those settings do their best work when there are conversion events to optimise towards.
Under the Standard, none of those feeds are allowed. That means no ad pixels, including Google’s and Meta’s conversion tags (ruling R-003). It means no conversion APIs or enhanced conversions. And it means no offline click-ID imports (ruling R-004). An offline import works like this: you store the Google Click ID from each ad click, then later hand that ID back to Google Ads, along with what the person bought and when. That is still customer data going back to the platform. The route doesn’t matter.
Here is what that means in practice:
- Conversion bidding stops working. Target CPA, Target ROAS, Maximise conversions and Maximise conversion value have nothing to learn from. Performance Max has no conversion goal to aim at.
- Retargeting goes. Without a pixel or an uploaded list (rulings R-002 and R-005), there’s no audience of past visitors to follow round the web.
- Platform reporting gets thinner. Your ad accounts will show clicks and spend, not sales. You’ll measure sales yourself (see below).
- Costs will probably rise for a while. If paid media is a large share of how you acquire customers, expect a period of higher cost per acquisition as you move to bidding that knows less. We don’t yet have figures to tell you how much, or for how long. We will publish pilot members’ before-and-after numbers, with their permission, as they come in. We haven’t received any yet.
If most of your customers come from search, word of mouth, email or repeat purchase, the cost will be smaller. If you run heavily on Performance Max or Advantage+, it will be real, and you should plan for it.
What you keep
The Standard is about what you give the platforms, not where you advertise. You can keep buying ads.
Google’s bid strategy guide lists several strategies that don’t need conversion tracking. Maximise clicks gets as many clicks as it can within your budget. Target impression share aims to put your ad at the top of the page, or anywhere on it, for a set share of eligible searches. Manual CPC lets you set your own maximum cost per click. Enhanced CPC, the old halfway house, has gone: Google converted remaining campaigns to Manual CPC in March 2025. On Meta, you can optimise for reach or link clicks rather than purchases.
What you get
Trust you can point to. Your listing on the register shows what you’ve declared, what we checked and when your certification runs to. Customers don’t have to take your word for it.
Probably no cookie banner in the UK. The Data (Use and Access) Act 2025 changed the UK’s cookie rules. Section 112 came fully into force on 5 February 2026 (S.I. 2026/82). It added an exception to the consent requirement for storage or access whose sole purpose is to collect statistics about how your service is used “with a view to making improvements to the service”. You still have to explain it clearly and give people a simple, free way to object. Any data can only be shared to help improve the service. The ICO’s guidance says the exception “does not apply to purposes related to online advertising”. That includes measuring whether someone viewed or clicked an ad. Once the pixels have gone, a site whose remaining storage is strictly necessary, or covered by that statistics exception, usually has nothing left to ask consent for. Check your own site before you remove the banner: an embedded video or chat widget can still need consent. This is general information, not legal advice.
Less legal exposure. The same Act raised the maximum fine for breaching the UK’s cookie and e-marketing rules (PECR) from £500,000 to UK GDPR levels: £17.5 million or 4% of global annual turnover. The fewer recipients your customers’ data goes to, the fewer places things can go wrong.
Fewer vendors. Most of the work is taking things out: tags, tag managers, audience connectors and the integrations that feed them. Your data map (clause NFS-4.1) gets shorter, and so does the list of contracts to check.
A simpler story for customers. “We don’t hand you to ad platforms” is easy to say, easy to check and easy to believe.
A migration order that works
- Map it first. List every tag, pixel, connector, upload and sync, including anything your agency set up (clause NFS-1.7). “Where data goes” and “Five questions for any vendor” will help.
- Turn off uploads and syncs. Stop customer list uploads, CRM and email audience syncs, offline conversion imports and conversion API connections. Remove the audiences built from them. These are the largest flows and the easiest to miss.
- Remove the pixels. Take out ad pixels, conversion tags and GA4, including anything loaded through a tag manager or a platform “channel” app.
- Switch bid strategies on the same day. Move Search campaigns to Maximise clicks, Target impression share or Manual CPC. Pause or rebuild Performance Max and Advantage+ campaigns, which have nothing left to optimise towards.
- Put your own measurement in place. Tagged links, cookieless analytics, promo codes and a “how did you hear about us?” question at checkout. Our guide “Measuring marketing without following anyone” covers the larger-spender tools.
- Run a baseline period. Leave the new set-up alone for a few weeks before judging it. Compare against the same weeks last year as well as the previous month.
- Then tune. Adjust keywords, bids, budgets and creative against your own sales data, not the platform’s.
The core rule is that customer data, including visitors, prospects and subscribers, never goes to an ad platform, or to anyone who uses it for their own purposes, ad targeting or measurement, by any route. Pixels (ruling R-003), conversions and click IDs sent back (ruling R-004), and uploaded or hashed audiences (rulings R-002, R-005) are all covered. Consent doesn’t cure a breach (clause NFS-1.3). Agencies act for you, and you’re responsible for what they set up (clause NFS-1.7). Buying ads is not restricted. Cookieless, aggregate counting is fine (clause NFS-2.1, ruling R-007). Your data map (clause NFS-4.1) is where you show the change.
Sources (12), checked 20 September 2026
- About Smart Bidding – Google Ads Help
- Determine a bid strategy based on your goals – Google Ads Help
- About Maximize conversion value bidding – Google Ads Help
- Multiply conversions with Performance Max – Google Ads Help
- About offline conversion imports – Google Ads Help
- Google Ads to deprecate enhanced CPC for Search and Display – Search Engine Land
- Bid strategies – Meta Marketing API documentation
- Advantage+ campaigns – Meta Marketing API documentation
- Data (Use and Access) Act 2025, section 112 – legislation.gov.uk
- What are the exceptions? Guidance on storage and access technologies – ICO
- Key aspects of the Data (Use and Access) Act take effect – Clifford Chance
- DUAA: the Commencement No. 6 Regulations are now in force – Womble Bond Dickinson