The Seqlense Regulatory Brief - Edition #31 EN

Regulatory Brief #31: two moves from words to action. In a decision dated 22 October, the CNIL fined Fnac Darty Participations et Services and Fnac Direct a total of EUR 7 million: after “Continue without accepting”, the Fnac app sent a user identifier and the products viewed to a third party to personalise and train its recommendation algorithm. Key lesson: personalisation or algorithmic training does not qualify as a strictly necessary tracker and requires prior consent (Article 82 of the French Data Protection Act). On the tokenised finance side, the Eurosystem published the report on its Appia consultation: 127 responses, broad support, and priorities on settlement finality, smart contract liability and key custody. Pontes has been live since 21 September 2026, with extended hours by mid-2027 and the Appia blueprint expected in 2028.