The UK Information Commissioner’s Office (ICO) is reviewing cookie and other online-tracking practices across the country’s 1,000 most frequented websites. Its goal is to make sure people receive clear information and a meaningful choice about non-essential tracking. By April 2026, the ICO reported that 99% of those sites met its cookie-banner compliance standards, while a separate assessment found 95% made rejecting non-essential cookies as easy as accepting them.
What is the ICO’s cookie review?
Announced on 23 January 2025, the review is part of the ICO’s 2025 online-tracking strategy. The regulator said it would bring the UK’s 1,000 most frequented websites into compliance with data-protection law. Its work began with assessments of the top 200 sites; at the announcement, the ICO had raised concerns with 134 organisations. The ICO’s announcement describes the initial phase and the wider programme.
The review concerns more than banner design. It addresses whether people understand what tracking is for and can make a genuine choice. The ICO has pointed to potential harms such as people with gambling problems receiving more betting adverts based on browsing history, and LGBTQ+ people changing their online behaviour for fear of unintended disclosure. Stephen Almond, the ICO’s Executive Director of Regulatory Risk, said: “Uncontrolled tracking intrudes on the most private parts of our lives and can lead to harm.”
What the ICO’s compliance figures mean
The ICO reported two related but distinct results in 2026. Its updated guidance says 99% of the UK’s top 1,000 websites met its cookie-banner compliance standards. A separate ICO impact assessment says 95% offered a way to reject non-essential cookies as easily as accepting them. These figures measure different outcomes; the 99% figure should not be read as meaning that 99% met the separate rejection-ease measure.
The percentages describe the ICO’s assessment of the top 1,000 websites, not every UK website or every tracking practice. They also do not establish that any particular site is compliant: operators need to assess their own technologies, purposes and user choices against current law and guidance.
What UK cookie and tracking rules require
Under the ICO’s guidance, a website generally must tell people that it uses cookies, explain what they do and why, and obtain active, clearly given consent before using technologies that require consent. Continuing to browse or relying on a preselected setting is not the same as an active choice. A limited exception applies when a cookie is strictly necessary to provide an information-society service the user has requested—for example, remembering an online shopping basket or supporting online-banking security. See the ICO’s cookies and similar technologies guidance.
The ICO’s final Storage and Access Technologies guidance, updated 29 April 2026, covers more than conventional cookies. It addresses tracking pixels, device fingerprinting and other methods of storing information on, or accessing information from, a device. It explains how the Privacy and Electronic Communications Regulations (PECR) interact with the UK GDPR where relevant.
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Consent choices should be meaningful
A compliant banner needs to give people a fair way to refuse non-essential tracking, rather than making acceptance easy and refusal difficult. The ICO’s final guidance includes chapters on what counts as a “simple means of objecting” and on using the same storage or access technology for multiple purposes. Operators should consider both the choices shown to users and what happens behind the banner: technologies should be assessed by purpose, and consent should be managed accordingly.
Do I need consent for analytics after the Data (Use and Access) Act?
Not necessarily in every case, but an analytics label alone does not determine whether consent is required. Amendments to PECR made through the Data (Use and Access) Act allow storage or access technologies without consent for certain purposes, including statistical collection and improving website functionality. The ICO’s impact assessment also notes that government may create further exceptions and that advertising-related exceptions were under consideration. The applicable exception depends on the technology and its purpose, so operators should check the ICO’s current Storage and Access Technologies guidance before relying on an exemption.
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Can a website make me accept cookies or pay?
The ICO’s stated expectation is meaningful, fair choice over non-essential tracking, with a simple means of objecting. Its guidance addresses what qualifies as a simple means of objecting, but the figures and announcements summarized here do not establish a blanket rule for every “accept cookies or pay” arrangement. A site’s specific design and legal basis matter; users who believe a banner gives no genuine way to object can raise the issue with the website and consult the ICO’s current guidance.
How to check a website’s cookie banner
For a practical assessment, review the full path from the first banner to the site’s settings, then check the technologies and purposes involved. These checks reflect the ICO’s guidance and stated compliance expectations:
- Compare the choices: Is refusing non-essential tracking as easy to find and use as accepting it?
- Check the explanation: Does the site say what tracking technologies do and why they are used?
- Look beyond cookies: Does the review account for pixels, fingerprinting and other device storage or access methods?
- Match consent to purpose: Are technologies and purposes managed separately where necessary, including when one technology serves multiple purposes?
- Keep evidence and adapt: Can the operator demonstrate consent and purpose management, and update its approach when ICO guidance or legislation changes?
- Assess exceptions carefully: Is a technology genuinely covered by a PECR exception, rather than merely described as necessary or analytical?
The ICO’s 2026 impact assessment reports the separate rejection-ease result and discusses the PECR changes. For a site owner, the relevant question is not simply whether a banner appears, but whether the site’s complete tracking setup and choices meet the rules that apply to it.
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