Medium risk

Consent or pay — no free way to say no

Short answer: The only free option is to accept tracking. Visitors who say no have to pay or subscribe. This may not meet EU regulator guidance.

Is a “consent or pay” cookie wall allowed in the EU?

EU regulators have said a “consent or pay” choice is unlikely to give valid, freely given consent on large online platforms, and several expect a free option without tracking. The law is still being contested, so treat this as a risk to review rather than a settled breach.

How to fix it

  1. Offer a free option that doesn’t track, for example a version with non-personalised (contextual) ads.
  2. If you keep a paid option, keep the price reasonable and show the free choices just as clearly as the paid one.
  3. Write down why your approach is fair, especially if your site is large; regulators will ask.

How untick detects it

untick loads your pages in a fresh browser with no cookies and an EU locale, records network requests and cookies, inspects the consent banner and forms, and interacts with them the way a visitor would. When this issue is found, the report includes screenshots with the element highlighted, the evidence, and a fix tailored to your setup.

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