Cookie banner requires extra clicks to reject (Manage/Settings -> Reject) - dark pattern
This check looks at how many clicks it takes to reject cookies compared to accepting them. On this site, rejecting requires navigating through a 'Manage' or 'Settings' screen first, rather than a single click on the main banner, while accepting is a single click. This asymmetry is a recognised design pattern called a dark pattern. France's data regulator, CNIL, issued formal notices in 2025 treating any reject process requiring two or more clicks as non-compliant, and this is one of the most heavily enforced consent issues in Europe right now, with major companies penalised over this exact pattern. Reject is required to be a single click on the first layer of the banner, the same as accept. Your developer and privacy lawyer should reconfigure the consent banner so 'Reject All' appears directly on the first layer, at the same size and visual prominence as 'Accept All', with no need to open a settings panel first. Major consent platforms, including OneTrust, Cookiebot, and CookieYes, support this through configuration rather than custom code, so it's typically about an hour of work.
Why this matters
France's data regulator, CNIL, issued formal notices in 2025 treating any reject process requiring two or more clicks as non-compliant, and this is one of the most heavily enforced consent issues in Europe right now, with major companies penalised over this exact pattern. Reject is required to be a single click on the first layer of the banner, the same as accept.
How to fix it
Your developer and privacy lawyer should reconfigure the consent banner so 'Reject All' appears directly on the first layer, at the same size and visual prominence as 'Accept All', with no need to open a settings panel first. Major consent platforms, including OneTrust, Cookiebot, and CookieYes, support this through configuration rather than custom code, so it's typically about an hour of work.