Cookie wall
A cookie wall is a barrier that blocks access to a website or its content until the visitor accepts tracking cookies, with no way to continue without consenting.A cookie wall turns the consent question into a toll: accept the cookies or leave. Under the GDPR such consent is not freely given, because refusing has a detriment, and the EDPB's Guidelines 05/2020 say in so many words that a wall which blocks the content until the user clicks Accept does not produce valid consent. The EDPB's cookie banner task force added in 2023 that a banner must not give users the impression that they have to consent to access the site.
The variant called pay or consent, where the visitor can either accept advertising cookies or pay a subscription, is treated more carefully. In France the Conseil d'État annulled the CNIL's general ban on cookie walls in June 2020, and the CNIL published assessment criteria in May 2022: a real and fair alternative must exist, the price must be reasonable, and the paid option must not itself track. The EDPB's Opinion 08/2024 (April 2024) said that very large online platforms should offer a free alternative that does not rely on behavioral advertising, and the CNIL repeated in its September 2025 Google decision that cookie walls are not illegal in themselves if the alternatives are presented in a balanced way and consent is informed.
Elsewhere, Türkiye's KVKK guideline and Brazil's ANPD list cookie walls among the practices to avoid, and Switzerland's FDPIC accepts cookie paywalls if the price is proportionate. A wall whose alternative is hidden is also a dark pattern.