New EDPB guidance just dropped: useful insights for anyone building checkout flows in 2025

Team, the EDPB just released fresh recommendations on when online stores can require users to create an account: and it’s worth keeping on the radar as we shape FluentCart’s next iterations.

Here’s the punchline:

The EDPB suggests that, in many common e-commerce scenarios, guest checkout tends to be the more privacy-aligned option (especially for simple, one-off purchases).

Not a ban. Not a hard rule.

Just a clear regulatory preference grounded in “necessity” and “data minimisation.”

A few useful takeaways:

1. One-time purchases → guest checkout is usually the expected path

Because it’s hard to argue that a full user account is “necessary” for a single transaction.

1. Subscriptions → stronger justification for requiring login

Ongoing access, updates, and recurring billing make authentication part of the service itself.

1. Exclusive memberships → also a potential valid case

If the offer is truly restricted (invitation-only, verified status, etc.), the account becomes part of the contract.

1. Other reasons (order tracking, loyalty, future purchases, fraud checks) →

EDPB frames them as possible purposes, but usually not strong enough on their own to mandate an account.

Again, these are guidelines, not handcuffs.

But they’re a good reference point for dev decisions and UX defaults.

What does this mean for FluentCart?

It’s an opportunity, not a constraint:

• A clean, first-class guest checkout aligns with these expectations.
• Optional account creation (NOT forced) becomes best practice.
• Mandatory login for subscriptions remains fully compatible.
• Clear boundaries between purchase flow and marketing/loyalty features help keep everything compliant.

If the ecosystem moves this way, FluentCart can stay ahead by making “privacy-smart checkout” part of its value proposition: without limiting merchants who need more advanced flows.

Hope you find this useful :)

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