Only a few minutes into his session at the IAPP Privacy. Security. Risk. conference in Austin, Texas, WilmerHale Cybersecurity and Privacy Practice Group Co-Chair Reed Freeman, CIPP/US, did not mince words on the current status of the ePrivacy Regulation.

"The ePrivacy Regulation is a giant mess, it’s a bigger mess than the [California Consumer Privacy Act of 2018]," he said. "There is so much uncertainty about whether it is needed, what is required and what is the process for all of this. Nevertheless it is out there, and it might happen."

At the heart of the ePrivacy Regulation's issues is the matter of consent, but before Freeman broke down that problem, he offered attendees of his breakout session a recap of a trio of texts from European Union bodies.