CNIL-Compliant Cookie Banner Implementation

Overview

The Commission Nationale de l'Informatique et des Libertés (CNIL) enforces some of the strictest cookie consent requirements in the EU. Following its updated guidelines (Deliberation No. 2020-091 of 17 September 2020) and landmark enforcement actions — including the EUR 100 million fine against Google LLC and EUR 50 million against Google Ireland Limited (31 December 2021), and the EUR 60 million fine against Meta Platforms Ireland Limited (31 December 2022, later increased in subsequent actions totaling EUR 150 million across multiple decisions) — organizations serving French users must implement cookie banners meeting specific design and functional requirements.

CNIL Cookie Banner Requirements

1. Equal Prominence for Accept and Reject

The CNIL requires that the mechanism to refuse cookies must be as easy to use as the mechanism to accept them. This was the central issue in the Google and Meta enforcement actions — both companies provided a prominent "Accept All" button but required multiple clicks to reject cookies.

Compliant Design for Pinnacle E-Commerce Ltd: