Termly Migration Checklist: What to Verify After Switching CMPs

Introduction

*Updated for 2026 compliance practices.*

Switching consent management platforms (CMPs) is a significant undertaking for any website owner. Whether you're moving away from Termly or adopting it as your new CMP, a structured **Termly migration checklist: what to verify after switching CMPs** is essential to maintain GDPR compliance and avoid costly gaps. This guide provides a step-by-step verification process, drawing on official sources like the European Data Protection Board and GDPR.eu, and shows how GDPRChecker's scanner can validate your setup. We'll cover consent defaults, tag management, policy disclosures, and more, ensuring your migration doesn't introduce compliance risks.

What Is a Termly Migration Checklist?

A **Termly migration checklist: what to verify after switching CMPs** is a structured set of checks to confirm that your new consent management platform correctly controls cookies, trackers, and data collection in line with GDPR and ePrivacy requirements. When you switch CMPs, configurations can break: consent signals may not reach tags, pre-consent requests might fire, or your privacy policy could become outdated. This checklist helps you systematically verify that consent banners behave as expected, consent states are respected, and disclosures remain accurate.

Unlike a generic GDPR checklist, this guide focuses on the technical and operational gaps that often appear after a CMP migration. For broader compliance steps, see our GDPR checklist for small businesses.

Why Verifying After a CMP Switch Matters

Migrating CMPs isn't just a technical swap—it's a compliance-critical change. If your new CMP fails to block cookies before consent, you risk non-compliance with the ePrivacy Directive and GDPR. Regulators expect website owners to maintain control over data collection at all times. The EDPB emphasizes that consent must be freely given, specific, informed, and unambiguous; a misconfigured CMP can undermine all four.

Common post-migration issues include: - Tags firing before the user interacts with the banner. - Consent signals not being passed to Google Consent Mode or other frameworks. - Outdated cookie declarations in your privacy policy. - Broken reject buttons or missing opt-out mechanisms.

A thorough **Termly migration checklist: what to verify after switching CMPs** helps you catch these problems before they lead to complaints or enforcement actions.

How to Implement the Termly Migration Checklist Step by Step

1. Verify Consent Defaults and Banner Behavior

Start by testing the consent banner on your live site. Open an incognito window and visit your site. The banner should appear before any non-essential cookies are set. Check that: - No marketing or analytics cookies are dropped before consent. - The banner clearly explains what data is collected and for what purpose. - All cookie categories are listed with toggles set to "off" by default (unless strictly necessary). - The "Reject All" and "Accept All" buttons are equally prominent and functional.

Use GDPRChecker's scanner to confirm that pre-consent network requests are blocked. The scanner will flag any third-party domains contacted before consent, helping you close the **Cookie Banner gap**.

2. Close the Consent Mode Gap

If you use Google services, you must integrate your CMP with Google Consent Mode. After migrating, verify that consent states are correctly communicated to Google tags. Test both "granted" and "denied" states: - When a user accepts all, `analytics_storage` and `ad_storage` should be set to `granted`. - When a user rejects all, these should be `denied`. - Check that Google tags adjust their behavior accordingly (e.g., cookieless pings when denied).

Our Google Consent Mode v2 checker can help you validate this integration in detail.

3. Close the Google CMP Gap

Beyond Consent Mode, ensure that your CMP is properly recognized by Google's ad systems if you use Google AdSense, Ad Manager, or AdMob. Google requires a certified CMP that integrates with the IAB TCF, but even non-certified CMPs must pass consent signals correctly. After switching, check: - Your CMP's integration with Google's Additional Consent specification, if applicable. - That ad requests include the correct consent string. - That personalized ads are not served without consent.

Use GDPRChecker to scan for ad-related network requests and verify they respect consent signals.

4. Close the Cookie Banner Gap

The cookie banner is the most visible part of your CMP. After migration, ensure: - The banner design matches your site's branding and is not broken. - The banner reappears if the user clears cookies or uses a new device. - The consent log is recording choices correctly (timestamp, consent scope, user agent). - The banner is accessible and usable with keyboard navigation and screen readers.

A common mistake is forgetting to update the banner's content to reflect the new CMP's capabilities. For example, if your new CMP supports granular consent but your old banner only had an "Accept" button, you must update the text and options.

5. Close the Privacy Policy Gap

Your privacy policy must accurately describe your use of cookies and the CMP that controls them. After switching, update: - The list of cookies and their purposes (your new CMP may set its own cookies). - Instructions on how users can change their consent preferences. - The name of the CMP provider and a link to their privacy policy, if required. - Any changes to data processing agreements or sub-processors.

Refer to our privacy policy requirements guide for a full checklist. Then, use GDPRChecker to scan your policy page and ensure the disclosed cookies match what's actually found on your site.

6. Close the DSAR Gap

Data Subject Access Requests (DSARs) require you to provide users with their personal data, including consent records. After switching CMPs, verify that: - Consent logs are accessible and exportable in a machine-readable format. - You can retrieve consent history for a specific user (e.g., by IP address or cookie ID). - The new CMP's logs include all required fields: timestamp, consent scope, method of consent, and version of the consent notice.

If your old CMP stored consent logs, ensure you have retained them for the required period (typically at least as long as the data is processed).

Common Mistakes and How to Avoid Them

Even experienced developers can overlook critical details during a CMP migration. Here are the most frequent pitfalls and how to prevent them:

• **Forgetting to remove old CMP scripts**: Leaving legacy CMP code can cause conflicts, duplicate banners, or incorrect consent signals. Audit your tag manager and website templates to remove all references to the old CMP.
• **Not testing the reject flow**: Many teams only test the "Accept All" path. Ensure that rejecting all cookies actually prevents non-essential cookies from being set. Use GDPRChecker to simulate a reject action and verify zero non-essential network requests.
• **Ignoring subdomains and iframes**: Consent must be managed across all domains and subdomains where you set cookies. If your site uses iframes (e.g., for embedded videos), ensure the CMP controls those as well.
• **Assuming default settings are compliant**: CMPs often ship with default configurations that may not match your specific cookie usage. Customize the banner text, cookie categories, and vendor list to reflect your actual data processing.
• **Skipping post-migration scans**: A manual spot-check is not enough. Use an automated scanner like GDPRChecker to crawl multiple pages and detect cookies, trackers, and consent violations at scale.

How to Validate with GDPRChecker

GDPRChecker is designed to automate the verification steps in this **Termly migration checklist: what to verify after switching CMPs**. Here's how to use it effectively:

1. **Run a pre-migration baseline scan**: Before switching, scan your site to document existing cookies, trackers, and consent behavior. This gives you a benchmark.
2. **Scan immediately after migration**: Run the same scan on your staging or production site after deploying the new CMP. Compare results to identify new cookies, missing blocks, or changed consent flows.
3. **Test consent scenarios**: Use GDPRChecker's scanner to simulate different consent choices (accept all, reject all, no action) and verify that network requests match the expected behavior.
4. **Check policy alignment**: The scanner can compare detected cookies against your privacy policy's cookie declaration, flagging any discrepancies.
5. **Schedule recurring scans**: Compliance is not a one-time event. Set up regular scans to catch configuration drift or new trackers added by marketing teams.

For a deeper dive into cookie consent mechanics, see our guide on what is cookie consent.

Implementation Checklist

Use this numbered checklist to ensure you've covered all critical verification points after switching CMPs:

1. Remove all legacy CMP scripts and tags from your website and tag manager.
2. Verify the new consent banner appears on all pages, including subdomains.
3. Test that no non-essential cookies are set before consent (use incognito mode and GDPRChecker).
4. Confirm that "Reject All" and "Accept All" buttons work correctly and are equally prominent.
5. Check Google Consent Mode integration: consent states are passed correctly for all Google services.
6. Validate that ad-related network requests respect consent signals (if applicable).
7. Update your privacy policy to reflect the new CMP, cookie list, and consent mechanism.
8. Ensure consent logs are being recorded with all required fields and are exportable.
9. Test the consent experience on mobile devices and different browsers.
10. Scan your site with GDPRChecker after migration and fix any flagged issues.
11. Document your CMP configuration and verification results for accountability.
12. Schedule a follow-up scan within one week to catch any late-appearing issues.

FAQ

What is Termly migration checklist: what to verify after switching cmps? It's a structured set of checks to ensure your new consent management platform correctly controls cookies, trackers, and data collection after migrating from Termly or any other CMP. The checklist covers consent defaults, tag triggers, policy updates, and scanner verification to maintain GDPR compliance.

Do I need Termly migration checklist: what to verify after switching cmps for GDPR? Yes. GDPR requires that consent be informed and freely given, and that you demonstrate compliance. After switching CMPs, you must verify that the new setup respects user choices and doesn't introduce gaps. This checklist helps you systematically confirm compliance.

How do I implement Termly migration checklist: what to verify after switching cmps? Start by removing old CMP code, then test banner behavior, consent signals, and cookie blocking. Update your privacy policy, check Google Consent Mode integration, and scan your site with GDPRChecker. Follow the step-by-step guide and numbered checklist in this article.

How can I verify Termly migration checklist: what to verify after switching cmps with a scanner? Use GDPRChecker to scan your site before and after migration. The scanner detects pre-consent network requests, checks consent signal propagation, and compares detected cookies against your policy. It automates the verification of consent defaults and reject flows.

What are common Termly migration checklist: what to verify after switching cmps mistakes? Common mistakes include leaving old CMP scripts active, not testing the reject flow, ignoring subdomains, assuming default CMP settings are compliant, and skipping post-migration scans. These can lead to unauthorized data collection and GDPR violations.

Which cookies and trackers should I check for Termly migration checklist: what to verify after switching cmps? Check all non-essential cookies and trackers, including analytics, marketing, and social media pixels. Pay special attention to Google tags, Facebook Pixel, and any third-party embeds. GDPRChecker's scan will identify all detected cookies and their consent status.

How often should I review Termly migration checklist: what to verify after switching cmps? Review the checklist immediately after migration, then again after one week. After that, incorporate it into your regular compliance review cycle—at least quarterly or whenever you add new tags, update your privacy policy, or change CMP configurations.

What evidence should I keep for Termly migration checklist: what to verify after switching cmps? Keep records of your pre- and post-migration scans, consent log samples, screenshots of banner behavior, and documentation of your CMP configuration. This evidence demonstrates your accountability under GDPR and can be crucial if you face a regulatory inquiry.

Conclusion

A **Termly migration checklist: what to verify after switching CMPs** is your safeguard against compliance gaps that can emerge during a CMP transition. By methodically verifying consent defaults, tag management, policy disclosures, and DSAR readiness, you protect user privacy and your business's reputation. Use GDPRChecker's scanner to automate the validation process and catch issues that manual testing might miss. For more foundational knowledge, explore our guides on what is GDPR and what is ePrivacy.

Next step

Run a GDPRChecker scan to validate consent behavior, trackers, and disclosures after you implement the checklist above.

Comparison: common implementation approaches

| Approach | Best for | Evidence to retain | Trade-off | | --- | --- | --- | --- | | A shared consent record | Smaller sites with one banner and a limited set of tags | Consent choice, timestamp, policy version, and affected pages | Requires a reliable process when the banner changes | | A tag-manager based record | Teams that control analytics and advertising tags centrally | Consent defaults, trigger conditions, publish history, and test results | Can miss scripts added outside the tag manager | | A CMP or external consent platform export | Sites with multiple domains, vendors, or regional workflows | Vendor configuration, consent events, retention settings, and audit exports | Adds provider configuration and recurring review work |

Choose the approach that matches the site's tracking complexity, then verify that the stored evidence can explain what a visitor saw and what tags were allowed at that time.

Practical examples

Example 1: A small ecommerce site

A shop changes its cookie banner wording before a seasonal campaign. The operator records the previous and new banner version, tests Reject all and Accept all, and stores screenshots plus the resulting network checks. That creates a clear before-and-after record without relying on memory.

Example 2: A B2B lead-generation site

A marketing team adds a form analytics tag through its tag manager. Before publishing, it documents the consent category, the tag trigger, the privacy notice update, and a test showing that the request does not fire after a visitor rejects optional cookies.

Example 3: A multi-page content site

An editor notices that a new embedded video adds a third-party request. The team scans the affected pages, compares the result with the last scan, updates the cookie disclosure if necessary, and keeps the scan report with the deployment reference.

> This guide is technical implementation guidance for website owners. It is not legal advice.

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