DUAA’s Instigator Clause Makes Your WooCommerce Store Liable for Agency Pixels
The UK’s Data Use and Access Act added an instigator clause to PECR from February 5, 2026, making website operators directly liable for cookies placed by third parties — including tags your marketing agency installed in your GTM container. PECR fines now match UK GDPR levels at up to £17.5 million or 4% of global turnover. WooCommerce stores running agency-managed GTM containers must audit every tag firing before consent and understand that the agency is no longer the legal shield.