As privacy regulations evolve globally, cookie consent banners have become a near-universal feature of the web. But not all regions treat cookies the same way. Depending on where your users live, the consent model, banner design, and legal obligations can differ significantly.
This guide provides a clear overview of cookie banner expectations in major regions—including the EU, US, Canada, Australia, and Asia. Whether you're a developer, compliance officer, or product owner, this article will help you design cookie banners that comply with local laws, support accessibility, and build user trust.
Table of Contents
Europe (EU & UK)
🛡️ Laws: GDPR & ePrivacy Directive Mindset: Active, informed, opt-in consent
Under GDPR and the ePrivacy Directive, users must actively consent before non-essential cookies are set. Banners must be user-friendly, granular, and avoid manipulative design.
What your banner needs:
Buttons: “Accept All,” “Reject All,” and “Customise” must all be present and equally prominent.
Consent mechanics: No pre-ticked boxes. Users must choose explicitly what types of cookies they allow.
Content requirements: Clearly explain what cookies are used, for what purpose, how long they last, and who sets them (including third parties).
Styling: No “dark patterns.” The banner should be eye-catching but not obstructive, and must meet WCAG accessibility standards.
United States (CCPA, CPRA, State Laws)
🗽 Laws: CCPA, CPRA + state-level laws Mindset: Easy, transparent opt-out of personal data sharing and selling
US privacy law is a growing patchwork. California, Colorado, Connecticut, Virginia, and other states each have unique cookie banner requirements, but most revolve around giving users a clear right to opt out of personal data sharing.
What your banner should include:
Buttons: “Accept All,” and a “Do Not Sell or Share My Personal Information” button for California users. A “Customize” or “Manage Preferences” link is encouraged.
Consent mechanics: Opt-out is the default. Explicit opt-in is only required for sensitive data or minors in certain states.
Content: Users must be informed about what data is collected, why it’s collected, and how to exercise their rights.
Styling: Reject or opt-out options don’t need to match the “Accept” button in style—but must not be hidden or misleading.
🔗 Read the full breakdown by US state – including tables for California, Colorado, Connecticut, and more.
Canada (PIPEDA & Provincial Laws)
🍁 Laws: PIPEDA, Quebec Bill 64 Mindset: Transparent, meaningful, and informed consent
Canada emphasises informed and voluntary consent, though not necessarily opt-in for all cookies. Recent updates in Quebec and other provinces are pushing toward GDPR-style expectations.
Banner recommendations:
Buttons: “Accept” is required. “Reject” is optional but encouraged, along with a “Cookie Settings” link.
Consent mechanics: Consent must be informed and meaningful. Granular choices improve transparency.
Content: Explain what cookies are used (e.g., analytics, advertising), who sets them, and link to your Privacy/Cookie Policy.
Styling: Banners should be clear, accessible, and non-intrusive.
Australia
🇦🇺 Law: Privacy Act 1988 (currently under review) Mindset: Transparency-first; opt-in only for sensitive data
Australia doesn’t have a standalone cookie law, but the Privacy Act requires transparency. Explicit consent is only required for sensitive data or where cookies are not reasonably expected.
What’s expected:
Buttons: “Accept” is standard; “Settings” is optional.
Consent mechanics: Notification is often sufficient unless the cookies collect sensitive personal data.
Content: Explain what’s collected, why, and provide a link to your Privacy Policy. If data is transferred overseas, disclose that too.
Styling: Clear, non-intrusive, and in plain language.
Asia (Key Markets: Japan, South Korea, India, Singapore)
🌏 Laws: Vary significantly across countries Mindset: Historically notice-based, now trending toward consent
Asia’s privacy landscape is diverse. Some countries (e.g., South Korea, Japan) are moving toward consent-driven frameworks, especially where international data transfers or advertising is involved.
What your banner should do:
Buttons: At minimum, show an “Accept” or “OK” button. Include “Customise” options in privacy-forward countries.
Consent mechanics: Many regions allow cookies with just a notice, though opt-in is gaining traction in Japan and South Korea.
Content: Describe cookie types, data-sharing practices, and link to your Privacy Policy.
Styling: Display in the user’s local language, ensure visibility on first visit, and don’t block access to the main content.
General Best Practices
Regardless of jurisdiction, these cookie banner best practices help ensure legal compliance and a better user experience:
Plain language: Avoid legalese. Use simple, clear wording.
Timing: Show the banner on first visit—before setting any non-essential cookies.
Granular choices: Let users control categories like analytics, marketing, and functionality cookies.
Accessibility: Ensure the banner works with screen readers and can be navigated by keyboard.
Choice logging: Record and store user consent for future audits or legal proof.
No dark patterns: Don’t use color, layout, or language to trick users into consenting.
Summary Table: Global Cookie Banner Requirements (2025)
Region |
Accept |
Reject |
Customize |
Equal Prominence |
Granular Controls |
Policy Link |
Key Laws |
EU/UK |
✔ |
✔ |
✔ |
✔ |
✔ |
✔ |
GDPR, ePD |
US |
✔ |
✖* |
(✔/✖) |
✖ |
(✖/✔) |
✔ |
CCPA, CPRA, others |
Canada |
✔ |
(✖/✔) |
✔ |
✔ |
(✔) |
✔ |
PIPEDA |
Australia |
✔ |
(✖/✔) |
✔ |
✔ |
(✖/✔) |
✔ |
Privacy Act 1988 |
Asia |
✔ |
(✖/✔) |
(✔/✖) |
✔ |
✔ |
✔ |
Varies |
*In the US, the “Do Not Sell or Share My Personal Information” link is the closest equivalent to a “Reject All” button.
Conclusion
Cookie banners have become a defining element of privacy design—and a visible signal of your company’s commitment to transparency. While laws vary, the trend is clear: give users control, make choices easy, and explain your practices clearly.
The best banners do more than just avoid fines—they empower your users and build lasting trust.
Want help designing a cookie banner that complies with global privacy laws? Or ready to dive deeper into state-specific US requirements? We’ve got you covered.