Italy | Publication | December 2025
Focus on the fashion and luxury industry: Key developments regarding antitrust, unfair commercial practices and privacy laws.
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From all of us at Norton Rose Fulbright, happy holidays and a successful New Year!
(Link source: Vanity Fair Faces Regulatory Scrutiny Over Branded Content Practices)
On November 20, 2025, the French Data Protection Authority (CNIL) imposed an administrative fine of €750,000 on LES PUBLICATIONS CONDÉ NAST for non-compliance with cookie consent requirements on its website vanityfair.fr.
The investigation began in 2019 following a complaint filed by the NGO NOYB and included several online inspections and hearings between 2019 and 2025. In 2021, the company was reminded of its obligations and formally instructed to obtain user consent before placing non-essential cookies. Despite implementing corrective measures, subsequent inspections in 2023 and 2025 revealed persistent violations of Article 82 of the French Data Protection Act, which transposes EU rules on cookies and electronic communications (Directive 2002/58/EC and the GDPR).
The CNIL identified four key breaches:
The CNIL emphasized the seriousness of these infringements, citing the large number of affected users (over 6 million in France between June and October 2023) and the repeated nature of non-compliance despite prior warnings. In setting the fine, the CNIL also considered Condé Nast’s financial capacity and the central role of cookies in its advertising model.
This decision reinforces the CNIL’s strict approach to enforcing cookie consent rules and highlights the need for companies to provide clear information and implement effective mechanisms for managing user consent.
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On 13 November 2025, the European Parliament adopted (subject to certain amendments) the substantive Omnibus Directive which was proposed by the European Commission on 26 February 2025 (see our previous briefing here). On 16 December 2025, the European Parliament adopted further proposed amendments.
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In today’s fast-evolving legal landscape, litigation is becoming more complex, more international, and more strategic than ever before. Understanding the challenges, trends and lessons learned is critical for businesses and their litigation strategy and risk management.
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