The European Data Protection Board (EDPB) has stated that «pay or consent» models rarely constitute valid consent. However, the principle extends far beyond media companies and Schibsted. Consider download forms: «enter your email to get the guide.» Or apps: «share your location to use the service.» Or cookie banners: «accept all to see the content.» Consent is only valid if the user can refuse without negative consequences. If consent is the price for accessing a service, it is likely not freely given, regardless of whether the price is monetary or access.
**Practical point:**
Review all locations where you ask customers for consent — download forms, app access, cookie walls, customer registration. Does the customer get what they came for without consenting? If consent is the price for the service, it's probably not sufficient. Then you need to find another grounds for treatment — or change the terms.
Inspired by: The Norwegian Data Protection Authority