Checklist for GDPR-compliant cookie banners in 2025

In 2025, cookie compliance protects your business from regulatory fines while building user trust. The European Data Protection Board (EDPB) and national regulators are intensifying enforcement. Google paid €325 million (September 2025), Microsoft €60 million (2022), and Amazon €35 million (2020) for cookie violations. Regulators now target companies of all sizes.

If your website serves EU users, you need a truly GDPR-compliant cookie banner. As of March 2025, 2,245 fines totaling €5.65 billion have been issued. GDPR fines reach 4% of global annual revenue or €20 million, whichever is higher.

Website cookie compliance ensures users understand what data you collect and why. It gives them genuine control over their information. A compliant cookie banner is the foundation of transparent, ethical data collection. Redacto's Consent Manager automates this process, making compliance achievable.

TL;DR

GDPR cookie compliance in 2025 requires explicit consent before non-essential cookies load, with clear explanations, equal accept/reject options, granular controls, and easy withdrawal. Avoid dark patterns and keep detailed consent records, using geotargeting for different regions. Fines can reach €20M or 4% of global revenue. A certified CMP like Redacto automates blocking, documentation, and compliance.

The 2025 Enforcement Shift

The biggest change in 2025 is intensified enforcement of "prior consent" requirements and crackdowns on dark patterns. Regulators now actively penalize websites that set cookies before obtaining explicit consent or use manipulative design to pressure users into accepting tracking. The focus is on execution: verifying actual consent, checking records, and assessing user experience design.

Essential Compliance Checklist

Your cookie banner must deliver clear information, explicit consent, and genuine user choice. 

1. Clear Information - Explain what cookies you use, why, and retention periods in plain language. 

2. Explicit Consent - Use affirmative action (clicking accept) without pre-ticked boxes. 

3. Equal Buttons - Make reject and accept buttons identical in size, color, and position. 

4. Granular Options - Allow users to accept some cookies while rejecting others. 

5. Easy Withdrawal - Enable consent withdrawal as easily as providing it.

 6. Linked Policy - Display a clear link to your detailed cookie policy. 

7. No Cookies Before Consent - Only strictly necessary cookies load before user consent. 

8. Geolocation - Show GDPR-compliant banners to EU users; different banners for other regions. 

9. Consent Records - Maintain audit-ready documentation of what users agreed to and when.

Avoiding Dark Patterns

Dark patterns manipulate users into accepting cookies. Common violations include making "Accept" visually prominent while "Reject" is inconspicuous, hiding rejection options in secondary menus, using urgency language, or making rejection require multiple clicks. On September 1, 2025, the CNIL fined Google €325 million for dark patterns in Gmail ads and account creation. Regulators assess button size, color, placement, and interface design. Equal prominence means truly equal choice.

Compliance Beyond Europe

While GDPR is the strictest standard, other regions have similar rules. Brazil's LGPD requires informed consent. California's CCPA requires opt-out notices for data sales. If you serve multiple regions, use geo-targeted banners. Redacto's Consent Manager handles GDPR, CCPA, LGPD, and DPDPA with pre-built templates for each jurisdiction.

Why a Consent Management Platform Is Essential

Managing cookie compliance manually is a recipe for failure. Redacto's Consent Manager handles critical functions: automatic cookie scanning, script blocking before consent, automated consent collection and storage, multi-region support, and Google Consent Mode integration. Pre-built templates for GDPR, CCPA, DPDPA, and other regulations eliminate developer intervention. The platform synchronizes user consent choices and creates audit-ready documentation, transforming compliance into a competitive advantage.

Quick Implementation Roadmap

1. Audit cookies - Identify every cookie on your site and categorize by purpose
2. Review design - Ensure equal button prominence and no dark patterns
3. Verify consent loading - Confirm non-essential cookies don't load before consent
4. Test across devices - Verify functionality on desktop, tablet, and mobile
5. Document everything - Maintain detailed consent records for audits
6. Set up geotargeting - Implement region-specific banners if needed
7. Use Redacto - Redacto's Consent Manager automates the entire process with pre-built compliance templates

For personalized guidance, contact Redacto or reach out via WhatsApp.

FAQ

Do I need a cookie banner if I only use essential cookies?

No. Essential cookies (those necessary for site functionality) may not require a banner, but most websites use tracking cookies, which require consent.

Can I use legitimate interest as a legal basis for analytics cookies?

No. Current enforcement confirms that legitimate interest cannot justify non-essential cookies. Analytics and marketing require explicit user consent.

How do I implement compliance quickly?

Redacto's Consent Manager enables implementation in hours. Pre-built templates, automatic cookie detection, and one-click integration streamline the process. Contact Redacto or WhatsApp us for a demo.

Do I need different banners for EU and non-EU users?

Yes. Geo-targeting is essential. EU users need GDPR-compliant granular consent; other regions may receive different privacy choices appropriate to their jurisdiction.

What happens if I discover non-compliance?

Remediate immediately. Document the issue, implement corrective measures, and consider consulting your legal team about whether to self-report to regulators.