Do You Need a Cookie Banner If You "Don't Collect Data"?

The most common objection to adding a cookie banner: "it's just a brochure site / landing page, we don't collect personal data, no forms, no sign-up — why would we need a banner." The problem is that "we don't collect data" usually means "we don't collect data on purpose through a form," not "the site sets no cookies." Those are two different things.

What's almost certainly already setting cookies

• A Yandex Metrica or Google Analytics counter — even in basic visit-counting mode it sets its own identifiers and logs the IP address;
• Session recording and click/scroll heatmaps — these record a specific visitor's behavior, which falls squarely under identifying data;
• Chat and callback widgets (Jivosite, Tidio, and similar) — usually set their own cookie to tie a chat history to a visitor;
• Embedded YouTube/Vimeo videos, maps, and Google Fonts loaded from an external domain — can set cookies or send visitor data to a third-party server on page load, before a single click;
• Ad pixels (Meta, Yandex Direct, VK Ads) — if the site was ever used for retargeting, the pixel is probably still there.

In other words: if the site has a visit counter — and it almost always does, otherwise how would you know how many people visit — cookies are already being set. The question isn't "do we collect data," it's "did we get consent before it happened."

What if there really is nothing — no counters, no forms, no widgets

That site formally exists but is rare — a static page with zero external scripts. In that case a cookie banner isn't strictly required, since the law regulates data processing, not the mere existence of a website. But verify this technically rather than by assumption — many site builders and CMS platforms wire up trackers by default, even if the owner never consciously added them.

How to check what's actually on your site

The fastest way is opening browser DevTools (F12), the Application → Cookies tab, and checking the cookie list right after a normal page load, before clicking anything. If the list isn't empty, you need a banner. A manual audit is slow and easy to get wrong for scripts loaded dynamically or through a third-party widget — Cookiestack's scanner does the same thing automatically, crawling every page and listing cookies by category and provider.

Scan your site for free →

This article is for informational purposes only and is not legal advice. Consult a qualified data protection lawyer for your specific situation.