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GDPR Dark Patterns in Cookie Consent: An Automated Study of High-Traffic Websites Accessed from Denmark

Christos Ntemkas (Technical University of Denmark), Laura Vieira Teixeira (Technical University of Denmark), Lejla Islami (Technical University of Denmark), Gaurav Choudhary (Technical University of Denmark), Nicola Dragoni (Technical University of Denmark)

Future Internet
DOI: 10.3390/fi18090487 (Social Sciences)
License: CC BY

Abstract: This paper examines how often GDPR-relevant dark patterns appear in cookie-consent banners and how often users receive a choice that is free and informed. We use an adapted version of CCrawler to crawl 99 high-traffic websites accessed from Denmark, detect consent interfaces, and extract first-layer choice pathways and settings-layer elements for compliance-risk coding. We then assess detected banners against four GDPR-informed interface-level criteria: first-layer refusal availability, absence of pre-ticked or default-enabled options, relative accept/reject prominence, and non-obstructive presentation. These operational criteria are observable interface proxies rather than final legal determinations of GDPR compliance. Cookie banners were detected on 90 of 99 sites; the nine non-detections are reported separately and are not treated as evidence of non-compliance. The results indicate a structural imbalance: acceptance is usually available on the first layer, while refusal is often placed behind additional steps or settings dialogues. A subset of reachable settings interfaces also contained pre-ticked options. To place these observations in the European context, we compare the two directly comparable first-layer choice indicators with a recent 31-country study. Acceptance availability is close to that study’s Denmark-specific estimate, whereas first-layer rejection in our high-traffic Denmark-accessed sample lies between its Denmark-specific estimate and its 31-country aggregate. These cross-study comparisons are descriptive and are not treated as matched statistical estimates because the sampling frames and measurement procedures differ. The findings provide Denmark-specific, time-bounded evidence that known consent-interface asymmetries remain visible on high-traffic websites, together with a reproducible workflow for future audits.

Published on 17 Sep. 2026