Will Cookie Banners Disappear in 2025?

Anyone who surfs the internet has encountered them countless times: those annoying pop-ups that appear when visiting a website or online store, seemingly designed to do nothing but collect our data. These so-called cookie banners are a nuisance for many users. Often, they don’t even offer real choices—despite legal requirements—and instead push us to click “Accept All.” Many people don’t even understand what they’re consenting to and just want to get rid of the banner as quickly as possible. The fact is: whether they comply with data protection laws or not, they are always disruptive.

A regulation to curb these intrusive banners has been long overdue. Yet, so far, no effective solution has gained traction. However, there is now a glimmer of hope at the end of this long journey through data protection laws and cookie regulations: the new Regulation on Consent Management Services. A more familiar term might be Cookie Banner Regulation, which is the term I will use throughout this article.

The regulation was passed on September 4, 2024, with the goal of significantly reducing cookie banners and improving the user experience. In this article, we’ll break down the key aspects of the new Cookie Banner Regulation, analyze its impact on businesses and users, and weigh the arguments for and against it. Finally, we’ll explore the big question: Will cookie banners become obsolete in 2025?

Why Is a New Regulation on Cookie Banners Necessary?

The General Data Protection Regulation (GDPR) and the Telecommunications-Digital Services Data Protection Act (TDDDG) primarily determine how companies may collect and use user data online. The GDPR, in particular, has shaped the European digital landscape for years with its strict data protection requirements. It mandates that anyone processing user data through a website or online store must obtain active and informed consent from users.

Unlike the GDPR, the TDDDG focuses on protecting privacy and the processing of personal data in electronic communications. However, its scope is not limited to personal data—it also covers all types of information collected through the use of digital services. Both regulations share a common principle: access to users' devices for advertising purposes is only permitted with their explicit consent.

As a result, we are constantly confronted with requests for data usage while browsing the internet—especially through cookie banners. In theory, these banners are meant to ensure active and informed user consent before data processing, as required by the GDPR. But is this actually happening? In practice, cookie banners are often dismissed without being read, as users grow increasingly frustrated by their persistent appearance. As a result, true informed and active consent, in the spirit of the GDPR, is rarely given.

Who Actually Benefits from Cookie Banners?

This question is not easy to answer. Neither users nor businesses seem to gain a clear advantage. Instead, cookie banners often feel like a barrier, with requirements so complex that even data protection experts struggle to navigate them. Companies face the challenge of ensuring compliance without jeopardizing their business models. A key issue: there is no standardized system that universally covers all data protection requirements.

The Biggest Problems with Cookie Banners:

• Lack of Standardization: Implementation varies widely, leaving room for interpretation and inconsistency.
• Non-Compliance with Data Protection Laws: Many cookie banners use "dark patterns" or "nudging" techniques to manipulate users into giving consent.
• Complexity of Requirements: Companies must adhere to numerous privacy regulations, many of which are either unclear or not fully supported by common cookie banner solutions.
• Lack of Data Security: Over 90% of the websites we analyzed had data leaks.

Why a New Regulation Is Necessary

A new regulation is urgently needed to provide businesses with a legally compliant system for obtaining active and informed user consent. If a standardized solution is developed and approved by data protection authorities, companies can finally focus on their core business rather than constantly navigating compliance challenges.

This is exactly where the new Cookie Banner Regulation comes into play.

So, let’s take a closer look at what this regulation entails.

What Is the Cookie Banner Regulation / Consent Management Regulation?

The key driving force behind the new Cookie Banner Regulation is the Federal Ministry for Digital and Transport (BMDV). A central figure in this reform is Federal Minister Dr. Volker Wissing, who states:

“Effective data protection requires clear and understandable rules. With our reform of cookie consent, we are addressing exactly this issue: We want to reduce the flood of cookie banners and create a more enjoyable browsing experience for users […].”

But what exactly does Dr. Wissing mean by “Effective data protection requires clear and understandable rules”? After all, few areas are as heavily regulated as online data processing. However, he does have a point: these regulations are often far from easy to understand. One thing is clear—any form of data processing requires active, explicit, and informed user consent.

As mentioned earlier, there is currently no standardized system that enables businesses to legally obtain active and informed user consent with certainty. At the same time, many users find cookie banners disruptive—not to mention their often unattractive design. This is exactly where the new Cookie Banner Regulation aims to make a difference.

To address these challenges, the Telecommunications-Digital Services Data Protection Act (TDDDG) will be expanded with Section 26, titled “Recognized Consent Management Services, End-User Preferences”. This section introduces alternative systems to cookie banners: the so-called Consent Management Services.

But what exactly are the advantages of these new systems? Let’s take a closer look.

Consent Management Services (PIMS)

Consent Management Services, also known as Personal Information Management Systems (PIMS), are solutions designed to manage user consent and preferences. Their primary goal is to reduce the number of cookie banners on the internet by allowing users to centrally and granularly set their privacy preferences.

Simply put: Users will no longer have to confirm a cookie banner every time they visit a website. Instead, they can set their preferences once in a PIMS, and these settings will be automatically applied to visited websites.

How Does It Work?

For example, a user can choose to allow essential cookies but reject cookies used for advertising. When visiting a website, the PIMS automatically communicates these preferences to the site, eliminating the need for a repeated consent request. Additionally, these systems enable centralized management and easy modification of privacy settings.

Key Benefits of PIMS

• More user control: Users decide which data they share and with whom.
• Secure data storage: Personal information can be stored locally or in online storage systems.
• Automated consent management: Websites receive predefined user preferences, reducing interruptions.

In the future, online service providers and advertisers will need to interact with PIMS whenever they intend to process user data.

Now that we have an overview of Consent Management Services, let’s take a closer look at the key provisions of the Cookie Banner Regulation in the next section.

Key Provisions of the Cookie Banner Regulation 

What Are the Requirements for Consent Management Services?

The requirements for consent management services are outlined in the Cookie Banner Regulation. These requirements are categorized into general requirements, user-friendly procedures, competition-compliant procedures, and technological requirements for interoperability with digital service providers.

§ 3 General Requirements

• The service must store the user's consent preferences upon their first visit to a digital service.
• These preferences must be transmitted to the provider on each subsequent visit.
• Consent may only be managed if the user has been informed in advance about the following:
  • Who stores or accesses the data (service provider or third parties).
  • What specific information is stored or accessed.
  • Why the data is stored or used (purposes).
  • For how long the data is stored or utilized.
  • That consent can be revoked at any time, though previous data processing remains lawful.

Additionally, the consent and its associated details must be documented in a way that is easily accessible to the user.

§ 4 Requirements for a User-Friendly Procedure

• The user interface must be clear and transparent, enabling users to make informed decisions.
• Users must be able to view, modify, or withdraw their settings at any time, including a record of the date and time of changes.
• A prompt to review consent settings may only be displayed after at least one year, unless the user requests an earlier review.
• The service should allow users to export their saved preferences in commonly used file formats.

Consent management must be transparent, easily accessible, modifiable, and well-documented to ensure users can make informed decisions.

§ 5 Switching to Another Recognized Consent Management Service

• Users have the right to switch to another recognized consent management service at any time.
• Their existing consent settings must be transferable to the new service.
• The previous service must provide these settings in a commonly used and machine-readable format.
• The transfer of consent settings must be free of charge if the user requests it.

§ 6 Requirements for a Fair and Competitive Process

A consent management service must operate fairly and in compliance with competition regulations:

• All digital service providers must be able to obtain user consent under the same conditions.
• No provider may be excluded from receiving consent settings.
• The default settings of the service’s user interface must ensure that:
  • All providers are listed uniformly (e.g., alphabetically or chronologically).
  • User settings and related information are displayed in a standardized format.

§ 7 Technical Requirements for Interoperability with Digital Services

A consent management service must be configured so that:

• Digital services and software can detect whether a user is using a recognized consent management service.
• Digital services can send consent requests through this service.
• Digital services can verify whether a user's consent settings are being managed.

Who Provides Consent Management Services and How Are They Evaluated?

How Do Consent Management Services Work?

The consent management process using recognized services, as outlined in Section 26 of the Telecommunications-Telemedia Data Protection Act (TDDDG), operates as follows:

• Use of a recognized service: The end user utilizes a recognized consent management service that centrally stores their privacy preferences.
• Granting consent: During the first interaction with a website that supports such a service, the user decides whether to grant or deny consent. These choices are recorded and stored by the service.

• Automatic transmission: On future visits, the service automatically transmits the stored consent preferences to the website, provided the site has integrated the recognized service.
• Reduction of consent requests: This means the user does not have to configure their settings repeatedly, reducing the number of consent prompts and improving the user experience.

• Essential information: Websites must provide users with key details to enable informed decision-making, including:
  • The identity of the data processor
  • The type of data being processed
  • The purpose and duration of data processing

• Website responsibility: The website remains responsible for ensuring that consent is valid and meets the requirements of the General Data Protection Regulation (GDPR).
• Role of the consent management service: The recognized service facilitates this process by centrally storing and managing consents, but it does not exempt the website from its legal obligations.

• Logging: The service records all user decisions regarding granted or denied consent.
• User control: Users can view, modify, or withdraw their stored consents at any time, ensuring transparency and control.

This process is designed to simplify consent management for users while ensuring GDPR compliance. It requires websites to integrate recognized consent management services and provide the necessary information to users.

Is The Use Of Consent Management Services Mandatory For Companies?

The regulation under Section 26(2) of the Telecommunications-Telemedia Data Protection Act (TDDDG) introduces recognized consent management services to offer users a more user-friendly alternative to traditional cookie banners. However, the use of consent management services remains voluntary for businesses. Companies are not obligated to adopt these services and may continue using traditional methods to obtain user consent. The regulation thus provides an additional option to simplify consent management for both users and providers without mandating its use.

How Do Consent Management Services Differ from Traditional Cookie Banners?

Now that we have explained consent management services in detail, let’s compare them to traditional cookie banners to highlight the key differences.

Table: Comparison of Consent Management Services and Cookie Banners

This table highlights the key differences between consent management services and traditional cookie banners. It becomes evident that consent management services aim to establish a standardized process, making it easier for both users and businesses to handle consent efficiently.

In the next sections, we will take a closer look at the impact of these services on companies and users.

How Does the Cookie Banner Regulation Impact Companies? 

According to the Federal Ministry, the new cookie banner regulation is intended to provide benefits for companies. But is that really the case? 

✅ Advantages for Companies

✅ Easier Compliance with Data Protection Requirements
By using a recognized consent management service, companies no longer have to determine how to implement their own consent management systems.
This can help reduce legal risks and administrative burdens, especially for smaller companies or those uncertain about compliance requirements.

✅ Improved User Experience
Users will experience fewer disruptive cookie banners and can manage their privacy settings centrally.
This could lead to longer website visits, higher conversion rates, and an overall more positive user experience.

✅ Competitive Advantage Through Transparent Data Protection Practices
Companies that adopt user-friendly consent solutions can strengthen consumer trust.
Privacy-conscious approaches may also be a decisive factor in contract bids or partnerships.

✅ Standardized Compliance
Using recognized consent services helps companies comply with legal requirements and minimize the risk of fines.

❌ Disadvantages for Companies

❌ Dependence on Third-Party Providers
Companies must rely on certified consent management services, which introduces costs and technical dependencies.
Changes in service offerings or price increases could create new challenges.

❌ Loss of Direct Control Over Consent Management
Companies can no longer fully determine how and when they collect user consent.
Customization to specific business needs might become more difficult.

❌ Potential Negative Impact on First-Party Data
If a user denies consent via a centralized service, this decision may apply to all connected companies, leading to reduced tracking data.
This could limit personalized advertising and web analytics.

❌ Additional Integration and Technical Requirements
Companies must integrate these services into their existing systems.
If the integration does not function smoothly, it could cause issues in data collection and processing.

Since the costs of using consent management services remain unclear, companies must weigh the cost-benefit ratio to determine if adoption is worthwhile.
Additionally, dependence on a few providers could limit flexibility—especially in terms of design and customization.

A critical concern is the loss of control over consent management.
A key question arises: How granular can companies define their consent settings?

In the long run, pre-configured privacy settings by users may pose a challenge. If users, by default, refuse all data collection except for functional cookies, companies must consider: How can they still collect data for personalized advertising and marketing?

Whether the advantages outweigh the disadvantages will likely depend on individual circumstances. Many companies may initially be hesitant and wait until reliable data on the impact of the new regulation becomes available.

How Does the Cookie Banner Regulation Impact Users?

After examining the effects on businesses, let’s now look at the potential advantages and disadvantages for users.

✅ Advantages for Users

✅ Fewer Disruptive Cookie Banners
Users no longer have to grant consent on every single website.
This leads to a more seamless and uninterrupted browsing experience.

✅ Centralized Consent Management
All consents are stored in one central location and can be modified or withdrawn at any time.
No more searching for cookie settings on each website.

✅ More Transparency & Better Control
Consent management follows a standardized format.
Users can clearly see who is using their data, what is being stored, and for what purposes.

✅ Privacy-Friendly Options
Users who do not want personalized advertising or tracking can opt out once centrally, instead of having to reject it on every individual website.

✅ Flexibility to Switch Services
Users can switch to a different recognized consent service at any time if they are dissatisfied with its functionality or privacy policies.

✅ Easy Export and Backup Options
Settings can be saved and exported in a machine-readable format.

A consent management service offers many benefits for users. Centralized management allows them to decide which information they want to share with companies. A particularly useful advantage is the reduction of intrusive cookie banners—but only if the respective website supports the service.

Overall, users gain more transparency about how their data is processed and can manage their preferences more easily.
Additionally, changes can be made later, as visited websites are listed within the service and remain accessible.

The New Cookie Banner Regulation: A Future-Proof Approach? Arguments For and Against

Whether the new cookie banner regulation will actually reduce the overwhelming number of cookie banners remains to be seen. However, it is worth taking a closer look at the arguments for and against this new regulation.

Arguments in Favor of the Consent Regulation 

✅ Fewer Consent Banners and a Better User Experience

I think we can all agree: cookie banners are incredibly annoying.
Especially when quickly researching or comparing information, it’s frustrating to be asked for consent on every single website.

This could change with the new regulation:
By managing consent centrally through a recognized consent management service, once-made settings will be automatically applied. Users will no longer have to click through numerous banners, making internet browsing smoother and more efficient.

✅ Greater Transparency in Data Processing

Many users don’t know which companies they have granted consent to and often struggle to revoke these settings.
This is particularly concerning when it comes to tracking and personalized advertising, as many users may wish to change their minds later.

Consent management services provide users with a central overview of their preferences—similar to a password manager.
This allows them to easily adjust their choices without having to search through every individual website.

✅ Simplified Consent Management for Businesses

Companies could also benefit:

• Fewer intrusive cookie banners mean a cleaner web design and an improved user experience.
• Transparent and user-friendly data protection can help build visitor trust.
• Businesses will no longer need to develop their own consent management systems, as standardized services will handle consent administration.

For small and medium-sized enterprises (SMEs), this means less effort, lower costs, and automatic compliance with evolving data protection requirements.

✅ Enhanced Privacy and Security

Recognized consent management services are subject to strict data protection regulations and are reviewed by independent data protection authorities.
This reduces legal risks for businesses, many of which currently use cookie banners that fail to meet data protection requirements—often without realizing it.

Some of the most problematic issues include:

• Dark patterns and nudging that manipulate users into giving consent (often in ways that are not legally compliant).
• Lack of transparency regarding how collected data is actually used.

The new regulation could help minimize fines and legal challenges associated with non-compliant cookie banners.

✅ Ensuring Fair Competition

The regulation ensures that large platforms do not gain an unfair advantage by nudging users into granting consent.
Recognized consent services must not have any financial interest in whether users give or deny consent, ensuring an objective consent management process.

This creates equal competitive conditions for businesses—regardless of their size—and fosters a fair digital advertising and data market.

Arguments Against the Regulation

❌ Technical Implementation for Businesses

Many companies already have their own consent management systems, which often do more than just handle user consent.
Over the years, they have developed tailored solutions that seamlessly integrate into their technology stack.

The new requirements would force businesses to modify or replace existing systems—leading to additional costs and development efforts.
Moreover, it remains unclear how long the transition period for implementation will be, which could put companies under significant time pressure.

❌ Dependence on Centralized Consent Management Services

While centralization has its advantages, it also makes the system more vulnerable to data breaches and cyberattacks.
Technical issues or security flaws could lead to widespread data protection violations.

The key question remains: Are there sufficient security measures in place to prevent misuse or unfair market conditions?

❌ Lower Advertising Revenue for Digital Businesses

If more users decline consent through a centralized system, companies will have fewer opportunities to serve personalized ads.
Currently, many users accept cookie banners out of convenience (“Accept all” to quickly close the pop-up).

With the new regulation, many may simply reject all non-essential cookies, significantly reducing the data available to businesses.
This would impact:

• Google Analytics & Ads
• Targeted marketing campaigns
• Personalized advertising

Companies that rely on ad revenue—such as news websites or free online services—could be particularly affected.
Potential consequences might include more paywalls or subscription models to compensate for lost revenue.

❌ Unclear Implementation and Legal Gray Areas

Several questions remain unanswered, such as:

• What happens if a user refuses consent via a recognized service, but a website requires certain data to function?
• Who is responsible if a consent management service malfunctions or is hacked?

These uncertainties could lead to legal challenges for both businesses and data protection authorities.

❌ Risk of Businesses Circumventing the Rules

Companies that rely on user data may look for ways to bypass the regulations.

Potential loopholes include:

• Reclassifying applications to continue processing data without consent
• Arguing that data collection is “necessary processing” under GDPR to avoid requiring explicit consent
• Large platforms and ad networks finding creative ways to access user data despite restrictions

This could create a new legal gray area, posing additional challenges for data protection authorities.

❌ Scope and International Challenges

The cookie banner regulation applies only in Europe.
International companies will still need to comply with various data protection laws and may have to run multiple systems in parallel.

This makes implementation complex and potentially less attractive for global businesses.

❌ Adoption and Implementation by Businesses

A crucial point: Using the recognized consent services is voluntary.
This means:

• Many businesses may continue using their own solutions, slowing adoption
• Fewer participating companies = fewer real-world insights, making it difficult to assess the regulation’s effectiveness

Additionally, technical barriers could discourage businesses from adapting their existing systems—especially if costs and implementation efforts are high.

❌ Costs and Technical Integration

There is currently no information about the cost of using the new consent services.
Small and medium-sized businesses, in particular, may struggle with both financial and technical aspects of integration.

If costs and effort are too high, willingness to adopt the system could drop significantly.

❌ Restrictions on Individual User Choice

It remains unclear how granular users will be able to set their preferences.

While some users may prefer centralized consent management, others may want to decide on a website-by-website basis.
If companies exclusively support centralized consent services, users could be forced into a system with limited flexibility—without a real alternative.

Will Cookie Banners Really Disappear in 2025? A Conclusion

Whether the cookie banner regulation will be successful largely depends on how many providers offer the required consent management services and how well users adopt them.

The new regulation aims to enhance digital privacy by enabling centralized consent management. The objectives are clear: fewer intrusive cookie banners, greater transparency, and easier control over personal data. At the same time, it seeks to ease the burden on businesses by introducing a standardized procedure for handling user consent.

However, the regulation also comes with challenges. Companies must adapt their technical systems, which can be particularly costly and time-consuming for smaller businesses. Additionally, there is a risk that some providers may attempt to bypass the new rules by reclassifying their data processing practices. The reliance on centralized consent services also raises concerns: Who oversees these services, and how can their neutrality and independence be guaranteed?

Another key concern is the economic impact. If a significant number of users refuse consent by default, personalized advertising models could be at risk. Many digital platforms, news sites, and smaller online businesses rely on ad revenue, meaning more content could end up behind paywalls or alternative revenue streams might become necessary.

Despite these challenges, the regulation represents a crucial step toward a more user-friendly and privacy-conscious internet. It sends a strong signal against the overload of consent requests and establishes a legal framework for greater transparency and control.

That being said, the introduction of this regulation does not mean the immediate disappearance of cookie banners—at least not overnight. As long as not all websites and businesses implement the new system, many will continue relying on traditional cookie banners. Additionally, legal gray areas remain: Some companies might reclassify tracking technologies or develop alternative data collection methods to avoid requiring user consent.

In the short term, little will change—cookie banners will not completely vanish in 2025. However, in the long run, the regulation could lead to more centralized consent management, reducing the need for individual banners. The biggest challenge will be ensuring fair and consistent enforcement so that the regulation achieves its intended effect.

➡ Conclusion: Cookie banners won’t disappear overnight, but their prominence could significantly decline due to the new regulation. 2025 is likely to be a transition year rather than the definitive end of cookie banners.