Cookie Wall
A website pattern that blocks access unless the user accepts non-essential cookies — generally not valid consent under GDPR, ePrivacy and EDPB guidance.
Full Definition
A cookie wall (sometimes called a 'take-it-or-leave-it' consent model or 'cookie paywall') makes access to a website or service conditional on the user accepting cookies, trackers or similar technologies that are not strictly necessary for the requested service. The user has two choices: accept everything or leave. The European Data Protection Board's Guidelines 05/2020 on consent are explicit that this does not produce 'freely given' consent as required by GDPR Article 4(11) and Recital 42 — the user has no real choice.
Several national DPAs have taken enforcement action against cookie walls in advertising-funded contexts. A nuanced sub-pattern — the 'pay-or-consent' model, where the user can either accept tracking or pay for a tracker-free version — has produced split regulator responses: Austria's DSB and the Italian Garante have accepted it in specific circumstances; the French CNIL and the EDPB's Opinion 08/2024 are sceptical, finding that the price-point and the practical availability of a genuine alternative determine whether the consent remains free. The pattern is governed primarily by GDPR Article 7 and ePrivacy Article 5(3), and secondarily by national ePrivacy implementations.
Related terms
Lawful Basis
A legal justification under GDPR for processing personal data — one of six bases must apply before processing can begin.
Opt In
A consent model in which a user must take affirmative action — such as ticking an unchecked box — before personal data is processed for the specified purpose.
European Data Protection Board (EDPB)
The EU-level body of national Data Protection Authorities that issues binding decisions, guidelines and consistency opinions under the GDPR.
Relevant regulations
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