I am aware that technical cookies don't need consent, only marketing cookies need consent.

However, if my site only uses functional cookies, do I still have to display a cookie banner that says what the cookies are used for?

1 Answer 1


There doesn't seem to be any legal requirement to show banners to announce the use of strictly necessary cookies ("functional cookies").

However, the GDPR's transparency principle requires you to disclose the purpose and legal basis for all processing of personal data. This could be done via a banner, but more commonly via a site-wide privacy policy. The GDPR requires such information to be provided at the latest at the time when personal data is collected. A layered disclosure approach could use banners to alert visitors to the privacy policy, but I'd want to avoid this to prevent confusion with non-compliant consent banners.

Of course, GDPR only applies when the cookies are used for processing of personal data. Cookies are handled more specifically by the EU's ePrivacy directive, for which each country has it's own implementation. You should therefore check with local laws and guidance from your local data protection agency.

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