EU Regulation 2016/679 - Decision Register

ARTICLE 7 GDPR / ENFORCEMENT GUIDE

Article 7 GDPR Fines, Consent & Cookie-Banner Enforcement

The conditions for valid consent. Combined with Article 4(11) (consent definition) and Article 5(3) ePrivacy (cookie placement), Article 7 underlies the bulk of ad-tech and cookie enforcement across the EU.

Statutory cap (GDPR)

Art 83(5) upper tier

Max fine

€20M or 4% turnover

Largest cookie fine

€150M (Google CNIL)

Cookie standard set

Jan 2022 CNIL

Key CJEU case

Planet49 C-673/17

EDUCATIONAL ONLY

This page is a reference summary of a published regulator decision. It is not legal advice. Consult a qualified data protection lawyer for advice on your specific situation. The UK GDPR is a separate regime from the EU GDPR following Brexit. Always read the source decision in full before relying on any figure or quote.

FULL ARTICLE TEXT

Article 7 in full

Article 7: Conditions for consent

1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data.

2. If the data subject's consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of this Regulation shall not be binding.

3. The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.

4. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.

And from Article 4(11): "consent" of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Full text on EUR-Lex (CELEX 32016R0679, Article 7).

What valid consent requires

Article 4(11) and Article 7 together define what constitutes valid consent. Four cumulative elements: freely given, specific, informed, unambiguous. Each element has been the subject of substantial DPA and court interpretation. Freely given means the data subject has a genuine choice and is not coerced; this is the dimension at issue in the "refuse as easily as accept" cookie cases. Specific means consent is for an identified processing operation or operations, not for general or open-ended use; this is the dimension rejecting bundled consent. Informed means the data subject has the necessary information to understand what they are consenting to, satisfying Articles 12-14 transparency. Unambiguous means the consent must be expressed through a clear affirmative action; this is the dimension rejecting pre-ticked checkboxes (Planet49, C-673/17).

Additionally, Article 7(3) requires that withdrawal of consent be as easy as giving it. This is the parallel principle to the cookie-banner refusal principle in the ongoing-consent dimension. A controller cannot make withdrawal harder than giving consent (e.g. requiring postal mail to withdraw consent that was given by clicking a button).

The GDPR-ePrivacy interaction for cookies

Cookie placement and similar storage/access operations on a user's terminal equipment are governed by Article 5(3) of the ePrivacy Directive (2002/58/EC, as amended by Directive 2009/136/EC). Article 5(3) requires user consent for such storage/access, with a narrow exception for cookies strictly necessary for the requested service. The Directive is implemented in each Member State through national law: Article 82 of the Loi Informatique et Libertés in France, the Privacy and Electronic Communications Regulations 2003 in the UK, the Telekommunikation-Telemedien-Datenschutz-Gesetz in Germany, and analogous frameworks in other Member States.

The substantive concept of consent under these national ePrivacy implementations is interpreted by reference to Article 4(11) GDPR. So cookie enforcement against a controller is typically formally framed as an Article 82 LIL (or equivalent) infringement, but the doctrinal analysis tracks GDPR consent principles. This is why the CNIL's cookie decisions cite EDPB guidance and CJEU case-law on consent even though they are formally not GDPR enforcement.

Landmark consent and cookie fines

Google €150 million (CNIL, 2022): the leading authority on the "refuse as easily as accept" standard. Established that asymmetric accept/refuse UX infringes the freely-given requirement.

Facebook Ireland €60 million (CNIL, 2022): parallel decision on the same legal theory applied to the facebook.com banner.

Microsoft €60 million (CNIL, 2022): extension to bing.com, confirming that the standard applies across major search providers.

Amazon Europe Core €35 million (CNIL, 2020): earlier cookie decision focused on cookie placement without prior consent.

Amazon €746 million (CNPD, 2021): although formally framed on Article 6 lawful-basis grounds, the substantive issue is consent-vs-other-basis for behavioural-advertising processing. The leading authority on the boundary between Article 6(1)(b) contract and Article 6(1)(a) consent for ad-tech.

IAB Europe TCF (APD, 2022): the leading authority on consent-framework architecture. Established that the TC String constitutes personal data and that IAB Europe is a joint controller for its processing.

Meta Ireland €390 million (DPC, January 2023): the EDPB-instructed decisions rejecting contract-as-basis for personalised advertising on Facebook and Instagram, definitively establishing consent as the required basis for behavioural ad-targeting.

Common compliance failures

The recurring patterns in cookie and consent enforcement are well-documented. Asymmetric accept/refuse UX on cookie banners (the principal CNIL pattern). Pre-ticked checkboxes (the Planet49 prohibition). Bundled consent covering multiple unrelated processing purposes without granular choice. Consent obtained as a pre-condition for receiving a service where the processing is not actually necessary for the service. Consent-withdrawal mechanisms that are materially harder than the consent-giving mechanism. Failure to record and demonstrate consent (the Article 7(1) accountability dimension). Reliance on contract or legitimate-interests for processing where consent is the correct basis (the Amazon CNPD and Meta EDPB pattern).

Defensive controls

For cookie banners specifically: deploy a CMP that offers "Accept all" and "Reject all" on the first screen with equivalent visual weight; do not place tracking cookies before consent; provide granular per-purpose controls in a settings screen; provide a persistent settings icon for ongoing consent management; record consent events with sufficient detail to demonstrate compliance (timestamp, banner version, choices made).

For non-cookie GDPR consent: distinguish processing where consent is the correct lawful basis from processing under other bases; for consent-required processing, use a clear and prominent consent collection UX; avoid bundling unrelated purposes; surface withdrawal mechanisms (e.g. a single-click unsubscribe link in every marketing email); record consent provenance and version.

For special-category data (Article 9(2)(a) explicit consent): require an affirmative action plus an additional confirming step (e.g. tick-box plus confirming statement) to satisfy the higher explicit-consent standard.

Fine band you can expect

For small national controllers with cookie-banner failures, AEPD-style decisions are typically in the €1,000-€50,000 range. For mid-sized national controllers, CNIL and equivalent decisions reach €50,000-€2 million depending on user reach and duration. For major platforms (Google, Meta, Microsoft, Amazon), cookie and consent fines have ranged €35M-€150M, with the upper end reflecting both the user-reach scale and the deliberate continuation of non-compliant patterns notwithstanding regulator engagement.

FREQUENTLY ASKED

About Article 7 consent fines

What does Article 7 GDPR require for valid consent?
Article 7(1) requires that controllers be able to demonstrate that the data subject has consented to processing. Article 7(2) requires that requests for consent in written declarations be clearly distinguishable from other matters, in an intelligible and easily accessible form. Article 7(3) requires that consent be as easy to withdraw as to give. Article 7(4) requires that the conditional nature of consent (whether performance of a contract is conditional on consent) be taken into account. Read together with Article 4(11), consent must be freely given, specific, informed and unambiguous.
What is the 'refuse as easily as accept' principle?
Established in the CNIL January 2022 Google and Facebook decisions, the principle holds that a cookie banner must offer a refusal action no more burdensome than the acceptance action. A 'Reject all' button must be available on the same screen as 'Accept all', with equivalent visual weight. Multi-click refusal paths, hidden refusal options and dark-patterns favouring acceptance all infringe the freely-given requirement.
How does GDPR consent relate to cookie consent?
Cookie consent specifically is governed by Article 5(3) of the ePrivacy Directive (2002/58/EC), implemented in each Member State through national law (Article 82 LIL in France, PECR in the UK, TTDSG in Germany, the Decreto Legislativo 196/2003 framework in Italy). The substantive concept of consent under these national implementations is interpreted by reference to Article 4(11) GDPR. So cookie fines are typically imposed under the national ePrivacy implementation, but the doctrine of valid consent is GDPR-aligned.
Why isn't consent the right lawful basis for everything?
Consent is only one of six Article 6(1) lawful bases. For processing that is necessary for the performance of a contract (6(1)(b)), or for a legitimate interest of the controller balanced against the data subject's rights (6(1)(f)), consent is not required and is in fact often the wrong basis. Asking for consent for processing that is actually contract-necessary can render the consent invalid (because it is not 'freely given' in the relevant sense). The Amazon CNPD case and the Meta EDPB decisions are leading authorities on the boundary between consent and contract.
What is the typical fine for Article 7 consent failures?
Article 7 itself is in the Article 83(5) upper tier (€20M or 4% turnover). Cookie fines under national ePrivacy implementations follow analogous frameworks. The largest cookie fines (Google €150M, Microsoft €60M, Meta €60M) sit at the upper end. Smaller controllers face cookie fines in the €1,000-€50,000 range depending on jurisdiction and decision pattern.
What about consent for sensitive (special-category) data?
Article 9(2)(a) allows processing of special-category data on the basis of 'explicit' consent of the data subject. Explicit consent is a higher standard than regular consent: it requires an unmistakable affirmative action (typically a tick-box plus a written or oral statement). For health data, biometric data, religious or political-opinion data, the explicit-consent standard applies.
Are silent or pre-ticked consent boxes valid?
No. The CJEU ruling in Planet49 (C-673/17, October 2019) established that pre-ticked checkboxes do not satisfy the 'unambiguous' indication requirement. Consent must require an affirmative action by the data subject. This applies to GDPR consent generally and to cookie consent under ePrivacy.

CROSS-REFERENCES

Cases citing Article 7 / cookies

ARTICLE 7 / COOKIES

Google €150M CNIL (2022)

The leading 'refuse as easily as accept' cookie-banner authority.

Open reference →

CONSENT-CONTRACT BOUNDARY

Amazon €746M (2021)

The leading consent-vs-contract authority for ad-tech.

Open reference →

SUPERVISORY AUTHORITY

French CNIL Profile

Europe's leading cookie-enforcement authority.

Open reference →

SUPERVISORY AUTHORITY

Belgian APD Profile

IAB Europe TCF framework decision.

Open reference →

ARTICLE 5

Article 5 Enforcement

5(1)(a) fairness applied alongside Article 7 consent.

Open reference →

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SOURCES & CITATIONS

Primary sources

Figures as of May 2026. Verified against published DPA decisions.

REGISTER UPDATED 2026-04-28