Guidelines for cookie banners from NOYB and the implementation with CCM19

The well-known lawyer for data protection law Max Schrems founded the organisation NOYB (None of Your Business) to take action against companies that use illegal cookie banners on their website. Since then, the NOYB team has been regularly analysing cookie banners on websites in terms of user-friendliness, transparency and accuracy of content as part of a project.

In order not to risk a warning, it is therefore important that the cookie banner used on one's own website can withstand NOYB's strict guidelines. CCM19 comes with all the features for a correct configuration and we will show you below how to set up your cookie banner NOYB-compliant with just a few clicks.

1. Reject option directly in first view

NOYB criticizes that 81% of the analyzed cookie banners do not offer the possibility to reject all cookies with just one click in the first window. This can easily be ensured by integrating a reject button directly in the first window of the cookie banner:

Banner with reject button

In CCM19, you can easily set which buttons are displayed in the settings of your active theme:

Button configuration

Cookie Settings and Accept buttons are set by default. For the third button, simply select the "Decline" entry from the select box to additionally show the button. You can change the order as well as the color of the buttons as you wish.

2. Categories must not be preselected

In 15% of cases, NOYB has found that a pre-selection has already been made for website visitors in the banner and cookies or cookie categories have already been ticked without the user taking any action.
This pre-selection option is not available in CCM19 due to legal issues; accordingly, there can be no problems here.

3. Use buttons instead of inconspicuous text links

According to the analyses of NOYB, about 51% of the analysed websites try to increase the rate for approval by hiding the reject function as an inconspicuous text link in the intro text of the banner.

In CCM19, all interaction options relevant to Consent are displayed as buttons by default:

CCM19 banner

Accordingly, this item on the NOYB checklist is also satisfied by default with CCM19.

4. Sufficient contrast for buttons

According to research by NOYB, in 73% of cases an attempt is made to make it more difficult to refuse cookies by using weak contrasts. On the one hand, this is due to the fact that button and font color are not in sufficient contrast to each other. Then the font is difficult to read and the button is clicked less often.
In other cases, a rather inconspicuous color is deliberately chosen for the reject button, while the accept button is highlighted in a better color.

In CCM19 you can easily configure the button colors and it will even warn you if the contrast between button and font color is too low:

Contrast setting

The button color for the reject button can be set separately, so that you can also display the button in a contrasting color with just a few clicks:

Red reject button

Thus, this NOYB policy can also be easily met with CCM19.

5. Rejecting cookies must be as easy as accepting them

According to NOYB, 90% of all cookie banners make rejecting cookies unnecessarily difficult, primarily by requiring more clicks to reject cookies than to accept them. Some websites erect veritable click mazes that must be traversed to avoid accepting all cookies. This deliberately tests the patience of website visitors to make consent more likely. This form of influence is rightly heavily criticised by the NOYB project.
With CCM19 it is easy to ensure that visitors to your website can also reject cookies with a single click. To do this, all you have to do is display the reject button, as already described in point 1. This, like the Accept button, only requires one click, so rejecting cookies couldn't be easier.

6. Cookies in the category "Technically necessary" must really be essential for the website function

About a quarter of all websites analyzed make untrue statements about the technical necessity of cookies, according to NOYB. References to third-party cookies are often even missing completely. Since cookies may only be set without consent if they are absolutely necessary for the operation of the website, the definition is sometimes interpreted very broadly and bindings or cookies are declared to be technically necessary, although strictly speaking they are not

If in doubt, it is better to choose a category other than "technically necessary" for cookies or bindings. With CCM19 you can easily define the category for each integration and thus ensure that really only technically necessary elements are declared as such:

Category setting

So if you make truthful classifications here for each tool used, this NOYB guideline is also fulfilled.


NOYB's cookie banner guidelines are easy to comply with through careful configuration of CCM19. Much is already covered by the default settings and some rule violations, such as using text links instead of buttons, is not even feasible in CCM19 without more effort.

If you have any questions about the NOYB guidelines or the implementation with CCM19, you are always welcome to contact us by mail or phone. We will be happy to advise you!

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