Reject All” Must Be As Easy As “Accept All” – Even for Non-EU Websites
- Author: Arno Schlösser, DP-Dock GmbH
- Last updated: October 2025
- Category: Cookies, Data Security, Consumer Rights
A German court ruled in March 2025 that cookie consent banners must present a “Reject All” button as clearly and prominently as “Accept All” – and this applies to any website targeting users in the EU, regardless of where the company is based.
Who is affected?
- Companies inside and outside the EU/EEA (e.g. in the US, UK, Canada)
- Websites or apps that:
- Are accessible to EU users
- Offer services or content in EU languages
- Accept EU currencies or ship to the EU
- Use cookies or tracking for EU visitors
If you target the EU, you must comply with the GDPR and the ePrivacy Directive, including valid cookie consent.
Even if you are not subjected to german jurisdiction, enforcement trends in the EU are converging and design matters just as much as the legal basis.
Key takeaways from the ruling:
- Users must be given a genuine choice — “Accept All” and “Reject All” must be equally accessible
- “Reject All” cannot be hidden behind settings or multiple clicks
- Design that nudges users toward acceptance (so-called “dark patterns”) may violate consent rules
- Consent must be freely given, specific, informed, and unambiguous
Recommended actions:
- Audit your cookie banner and consent UX for EU users
- Implement a first-layer “Reject All” option
- Ensure no tracking or data collection occurs before consent
- Maintain records of user consent in case of regulatory inquiry
EU regulators have made it clear: the GDPR applies based on where the (targeted) users are, not where the company is. Find the court ruling here.
Need help?
If your company operates a website or app used by EU residents, it’s time to double-check your consent mechanisms. Reach out to your privacy team, or legal counsel for a compliance review.
DP-Dock GmbH can support you in an advisory capacity to ensure that the legal requirements of the GDPR and e Privacy Directive are implemented correctly.
Should you have any questions or require further information, please do not hesitate to contact us any time.
