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.
Why this matters
France's regulator, the CNIL, has taken the position that refusing cookies should be as simple as accepting them, and it has sanctioned several companies over cookie banners. Other European regulators have published similar guidance. Whether this applies to you depends on where your visitors are, so check with a privacy adviser. Offering a reject option on the first layer of the banner, equal in prominence to accept, is a common way to address it.
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.
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