What changed
This article describes the regulatory landscape in general terms and isn't legal advice. If you're unsure about your specific situation, consult a lawyer familiar with data protection rules in your recipients' countries.
Since mid-July 2026, "Track email opens" defaults to off for every new sequence, following recent guidance from EU regulators (notably France's CNIL) on how existing ePrivacy rules, and the UK's equivalent, PECR, apply to tracking pixels.
This applies to newly created sequences only. Existing sequences kept their previous setting, if any of them include contacts who haven't consented to tracking, review them and turn tracking off yourself.
This article explains why, what it means for your outreach, and how to manage tracking when your audience has mixed consent status.
Why this changed
Tracking pixels are covered by the EU's ePrivacy rules (and the UK's equivalent, PECR), which govern storing or accessing information on a user's device. Under these rules, non-essential trackers require the recipient's prior consent.
Regulators have made this explicit:
France (CNIL) has stated that email tracking pixels require prior consent from the recipient, and that "legitimate interest" is not a valid substitute.
Italy (Garante) has taken the same position: invisible tracking in emails needs informed, prior consent.
Other EU regulators and the UK's ICO apply the same underlying rules.
Consent here means the real thing: the recipient was informed about the tracking and
actively agreed to it before you sent the email. Burying it in a privacy policy doesn't qualify
👉 As the sender, you're the data controller for your recipients. Deciding whether you have a valid basis to track a specific contact's opens is your responsibility, not Hunter's.
What this means for your sequences
Because the setting applies to an entire sequence at once, plan sequences around the consent status of your audience:
Cold outreach / no consent: leave tracking off. This is already the default for new sequences.
Opted-in contacts who've agreed to tracking: you can turn tracking on for that sequence.
Mixed lists: split into two sequences rather than turning tracking on for a list that includes unconsented contacts.
💡 Hunter doesn't store or check consent per contact. Turning tracking on for a sequence turns it on for every recipient in it.
How to turn tracking on or off for a sequence
While open and link tracking are disabled by default, you can enable or disable these options in your email sequence settings.
Open your sequence in Sequences.
Go to the sequence Settings.
Inside the Tracking section, toggle "Track email opens" on or off.
A workaround for mixed lists: tag your contacts by consent status
Since Hunter can't track consent at the contact level, use tags to segment your leads before you send. This lets you build separate sequences for each segment — one for tagged, consented contacts with tracking on, one for everyone else with tracking off.
Go to your Leads.
Add a tag such as "tracking-consented" to contacts who've explicitly agreed to be tracked.
Filter your leads by that tag to pull up each segment.
Select the filtered leads and add them to a new or existing sequence directly from Leads. You can also duplicate an existing sequence's content if you want the same email for both segments, instead of writing it twice.
Check the "Tracking" toggle in each sequence's Settings before you send.
See more on how to tag your leads.
Measuring performance without open tracking
Open rates have limits as a metric regardless of this change, Apple Mail Privacy Protection, for example, pre-loads tracking pixels and can inflate opens for a meaningful share of inboxes. The metrics below work with tracking off and are closer to what actually matters:
Reply rate: the clearest signal your outreach is landing.
Click rate: keep in mind that link tracking works through redirect links and falls under the same consent rules as open tracking, so use it only in sequences sent to consented contacts.
Positive replies and meetings booked: what the campaign exists for in the first place.
To sum things up
Tracking email opens requires the recipient's prior, informed consent under EU and UK ePrivacy rules: a mention in your privacy policy isn't enough.
New sequences default to open tracking off. Existing sequences kept their previous setting, review them and turn tracking off for any that include unconsented contacts.
Tracking is per sequence, not per contact: there's no built-in consent field, so a sequence's setting applies to every recipient in it.
Use tags to separate consented from non-consented contacts, and send them in separate sequences.