Cookie banners case study

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Many organisations are using third-party cookie banners to meet their GDPR responsibilities. These banners often cause accessibility issues that you may not be aware of but will be flagged during accessibility testing and may have impacts on user experience of your websites.

This case study covers several examples of common in-use cookie banners and their accessibility compliance to form a "for information" reference guide to help you make accessible choices when it comes to cookie banner selection.

Since GDPR came into effect in 2018, most organisations follow regulation requirements to allow customers to make informed choices about their data collection when visiting websites and what cookies they will accept for data collection.

The most common way of encouraging website visitors to confirm their preferences when it comes to cookies is in the form of a banner presented on the website when a user first visits. These banners can work in a variety of ways, offering users different levels of customisability when it comes to cookie acceptance.

Some may give users only an overall selection of cookie types such as:

While other banners may give users the option to specifically allow / deny cookies from individual ad vendors or who they will allow their data to be shared with.

In most cases cookie banner contain links to cookie policies, interactive components such as checkboxes or toggle controls and instructive text which may be customised to organisation branding or colour schemes. These components all can introduce accessibility issues.

More information from the ICO on Cookies.

While cookie banners are often purchased or used as third-party components, they perform an important active administrative function for users to make decisions on what information they provide to an organisation and additional data processors. Because of this, it is within the responsibilities of the website owner to ensure they are using accessible cookie banners on their website, and the choice of which falls within the scope of the public sector accessibility regulations 2018 for applicable public sector bodies.

As part of this case study we have looked at the following cookie banners for accessibility compliance. All efforts have been made to test banners across a range of examples and ensure accuracy of results at the time of testing.

This resource is intended for informational use only, to help organisations understand their options when it comes to cookie banners and accessibility and is in not a criticism of any individual component. We have linked to the accessibility information of any cookie banners we mention (where available) in each of the individual banner guides.

The cookie banners:

Over the course of this case study we have documented many accessibility issues with cookie banner examples. The list below represented the most common accessibility issues we see with cookie banners and why they are a problem.

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