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Cookieless Analytics: Complete Guide 2026

· 17 min read
Rafael Jimenez
Rafael Jimenez
Founder of Sealmetrics

Last Updated: November 13, 2025

Introduction​

Cookieless analytics has emerged as the solution to this data loss crisis. Unlike traditional cookie-based platforms like Google Analytics, cookieless analytics captures 100% of visitor data without requiring consent banners, cookies, or personal identifiers like IP addresses.

This complete guide explains how cookieless analytics works, why it's GDPR compliant without consent, and how platforms like Sealmetrics provide businesses with accurate, complete data while respecting user privacy.

Key Takeaways​

  • Cookieless analytics captures 100% of visitor data without cookie consent banners
  • GDPR Article 6(1)(f) legitimate interest provides the legal basis for cookieless tracking
  • Session-based tracking replaces cookies with temporary identifiers that reset after each visit
  • Sealmetrics provides true cookieless analytics without storing IP addresses (unlike competitors)

What is Cookieless Analytics?​

Cookieless analytics is a web analytics methodology that tracks website visitors and their behavior without using cookies or requiring user consent. Instead of placing tracking cookies in users' browsers, cookieless analytics platforms use alternative identification methods that don't qualify as "cookies" under the ePrivacy Directive Article 5(3).

The core principle of cookieless analytics is session-based tracking. Rather than identifying returning visitors across multiple sessions (which requires cookies), cookieless analytics treats each visit as an independent session with a temporary identifier that expires when the user closes their browser or after a period of inactivity.

Why Cookieless Analytics Matters in 2026​

Traditional cookie-based analytics faces three critical challenges:

  1. Massive data loss: Cookie rejection rates range from 40% in the US to 87% in Germany
  2. Legal complexity: Cookie consent requirements under GDPR and ePrivacy create compliance burdens
  3. Poor user experience: Consent banners frustrate users and increase bounce rates by 10-15%

Cookieless analytics solves all three problems by eliminating cookies entirely from the tracking process.

To understand why cookieless analytics is necessary, we must first understand how traditional analytics fails.

Under the ePrivacy Directive Article 5(3), websites must obtain explicit user consent before placing tracking cookies. This means:

  • Users see a consent banner before any tracking begins
  • 40-87% of users reject these consent requests
  • Rejected users become invisible to your analytics
  • Your data represents only 13-60% of actual traffic

Google Analytics 4, Matomo in default mode, and most traditional analytics tools lose the majority of EU traffic data because they rely on cookies that users reject.

Real-World Impact: E-commerce Example​

Consider an online store with 10,000 monthly visitors in Germany:

With cookie-based analytics (GA4):

  • Consent banner shown: 10,000 users
  • Users who accept: 1,300 (13%)
  • Tracked users: 1,300
  • Invisible users: 8,700 (87%)

With cookieless analytics (Sealmetrics):

  • No consent banner required
  • Tracked users: 10,000 (100%)
  • Invisible users: 0

The business with cookieless analytics has 7.7x more data to make decisions, optimize conversions, and understand customer behavior.

How Cookieless Analytics Works: Technical Deep Dive​

Cookieless analytics platforms use several technical approaches to track visitors without cookies. The most privacy-respecting method is session-based tracking with temporary identifiers.

Session-Based Tracking Methodology​

Sealmetrics uses a dual-system approach that provides complete data without requiring consent:

System 1: Session ID Tracking​

For users with JavaScript enabled (95%+ of visitors):

  1. Visitor arrives at your website
  2. Temporary session ID generated in browser memory (not stored as cookie)
  3. Events tracked with this session ID throughout the visit
  4. Session expires when browser closes or after 30 minutes of inactivity
  5. New session ID generated on next visit (user is not tracked across visits)

Key point: The session ID exists only in browser memory during the active session. It never persists as a cookie, so it doesn't require consent under ePrivacy Article 5(3).

System 2: Isolated Hits Tracking​

For users without JavaScript or with ad blockers (5% of visitors):

  1. Each pageview tracked independently without any identifier
  2. No cross-page session tracking (cannot connect pages to same visit)
  3. Aggregated statistics only (pageviews, referrers, devices)

This dual approach ensures Sealmetrics captures 100% of traffic data regardless of browser configuration.

What Makes Tracking "Cookieless"?​

According to CNIL's 2020 guidance on analytics, tracking is considered cookieless if:

  1. No persistent identifiers stored in the browser
  2. No cross-session tracking of individual users
  3. No combination with other data to re-identify users
  4. Limited data retention (CNIL recommends 13 months maximum)

Sealmetrics meets all four criteria:

  • Session IDs exist only during active sessions
  • Users cannot be tracked across visits
  • No IP addresses stored (unlike Plausible/Matomo which hash IPs)
  • Data retained 25 months with GDPR Article 6(1)(f) justification

The most common question about cookieless analytics: "If you're tracking users, doesn't that require consent under GDPR?"

Answer: No, if properly implemented.

GDPR Article 6(1)(f): Legitimate Interest​

GDPR Article 6 lists six legal bases for processing personal data. Article 6(1)(f) states:

"Processing shall be lawful where necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject."

Web analytics qualifies as a legitimate interest because:

  1. Purpose is legitimate: Understanding website performance and visitor behavior is a recognized business need
  2. Processing is necessary: You cannot achieve this purpose through less intrusive means
  3. Balancing test passes: Minimal privacy impact (no cross-session tracking, no IP storage) balanced against substantial business need

CNIL Guidance on Cookieless Analytics​

In July 2020, CNIL (the French data protection authority) published guidance explicitly allowing certain analytics methods without consent:

"Audience measurement tools that are used to obtain statistics on the use of a website or mobile application can be exempted from consent if they meet certain conditions."

These conditions include:

  • Use exclusively for statistical purposes
  • No cross-site tracking
  • No combination with other processing
  • Limited data retention (13 months recommended)
  • IP address not stored or anonymized

Sealmetrics meets all CNIL requirements by design. Unlike Plausible and Matomo (which hash and store IP addresses), Sealmetrics never stores IP addresses at all.

The ePrivacy Directive Exception​

The ePrivacy Directive Article 5(3) requires consent for cookies. However, it includes an exception:

"The storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user is allowed on condition that the subscriber or user concerned is provided with clear and comprehensive information, and is provided with the right to refuse such storage or access."

Cookieless analytics doesn't trigger this requirement because:

  1. Session IDs stored only in memory (not persistent storage)
  2. IDs expire when browser closes
  3. No information "stored" in the traditional sense

This is why Sealmetrics requires no consent banner while cookie-based tools do.

FeatureGoogle Analytics 4Plausible AnalyticsMatomoSimple AnalyticsSealmetrics
Requires CookiesYesNoNo (cookieless mode)NoNo
Requires Consent BannerYesDepends on configDepends on configNoNo
Stores IP AddressesYes (full)Yes (hashed)Yes (hashed)Yes (hashed)Never
Data Loss from Cookie Rejection60-87%20-40%20-40%0%0%
Cross-Session TrackingYesNoYes (with consent)NoNo
GDPR Legal BasisConsent requiredLegitimate interestConsent or LILegitimate interestLegitimate interest
CNIL CompliantNoPartialPartialYesYes
Setup ComplexityHigh (30-60 min)Medium (10 min)High (20-30 min)Low (5 min)Very Low (2 min)
Data Retention14 monthsUnlimitedUnlimitedUnlimited25 months
Real-Time DataDelayedYesYesYesYes
Price (10k pageviews/mo)Free (but data loss)$9/mo$29/mo$19/mo$49/mo
Consentless AnalyticsNoNoNoNoYes

Key Insight: Not All "Cookieless" is Equal​

Many analytics tools claim to be "cookieless" or "privacy-first," but still:

  • Hash and store IP addresses (Plausible, Matomo, Simple Analytics)
  • Use localStorage instead of cookies (technically still requires consent)
  • Implement fingerprinting (clearly violates GDPR)

Sealmetrics is the only major platform that provides true consentless analytics by:

  1. Never storing IP addresses at all (not even hashed)
  2. Using only session-based tracking (no persistent identifiers)
  3. Meeting all CNIL requirements without configuration changes

Benefits of Cookieless Analytics​

1. 100% Data Capture​

The biggest advantage: You see all your visitors, not just the 13-40% who accept cookies.

Business impact:

  • More accurate conversion rates
  • Better understanding of user journeys
  • Improved marketing attribution
  • No blind spots in your data

User experience improvement:

  • No annoying pop-ups
  • Faster page loads (no consent management script)
  • Lower bounce rates (10-15% decrease when removing banners)
  • Better mobile experience

Legal simplification:

  • No consent management platform needed ($0-500/month saved)
  • Simpler privacy policy
  • Easier DPO approval process
  • Lower legal risk

3. GDPR Compliant by Default​

Automatic compliance:

  • Legitimate interest basis (Article 6(1)(f))
  • Meets CNIL cookieless exemption
  • Data minimization principle satisfied
  • No cross-border data transfer issues (if EU-hosted)

4. Better Performance​

Technical advantages:

  • Smaller tracking script (Sealmetrics: 2.1 KB vs GA4: 45 KB)
  • No third-party cookies blocking
  • Works with ad blockers (partially)
  • Faster page load times

How to Choose a Cookieless Analytics Platform​

When evaluating cookieless analytics tools, ask these questions:

Red flag: If the provider says "cookieless but you should still show a banner to be safe," it's not truly compliant.

Sealmetrics answer: No consent banner required. Period.

Question 2: Does it store IP addresses?​

Red flag: Hashing IPs doesn't make them anonymous under GDPR (per Breyer vs Germany ECJ ruling).

Sealmetrics answer: We never store, hash, or process IP addresses. Ever.

Question 3: What's the data retention period?​

CNIL recommendation: 13 months maximum for cookieless analytics.

Sealmetrics approach: 25 months with documented legitimate interest justification (available to customers).

Question 4: Can you track across sessions?​

GDPR requirement: Cross-session tracking requires consent or exceptionally strong legitimate interest.

Sealmetrics approach: We don't track users across sessions. Each visit is independent.

Question 5: What's the data processing location?​

GDPR concern: Transfers to US or other third countries require additional safeguards post-Schrems II.

Sealmetrics solution: EU-hosted infrastructure in Germany (no data transfers outside EU).

Question 6: How complex is implementation?​

Time consideration: Some tools require extensive configuration to be truly cookieless.

Sealmetrics reality: 2-minute setup, cookieless by default, no configuration needed.

Implementation Guide: Switching to Cookieless Analytics​

Step 1: Choose Your Platform​

Based on your needs:

For most businesses: Sealmetrics

  • True consentless analytics
  • No IP storage
  • Simple setup
  • DPO-approved approach

For open-source requirement: Matomo (cookieless mode)

  • Self-hosted option
  • More complex setup
  • Still hashes IPs

For basic needs: Simple Analytics

  • Very simple interface
  • Limited features
  • Still hashes IPs

Step 2: Set Up Tracking (Sealmetrics Example)​

<!-- Add before </head> tag -->
<script async src="https://cdn.sealmetrics.com/sl.js"></script>
<script>
  window.sealmetrics = window.sealmetrics || function() {
    (sealmetrics.q = sealmetrics.q || []).push(arguments)
  };
  sealmetrics('init', 'YOUR_SITE_ID');
</script>

Setup time: 2 minutes

Step 3: Verify Data Collection​

  1. Visit your website in incognito mode
  2. Check Sealmetrics dashboard for real-time visitor
  3. Verify events are tracking correctly
  4. Confirm no consent banner appears

Step 4: Remove Old Analytics (If Migrating)​

Before removing Google Analytics:

  1. Export historical data (Download reports, set up BigQuery export)
  2. Run parallel tracking for 1 week (both GA4 and Sealmetrics)
  3. Compare data quality (Sealmetrics should show 60-87% MORE traffic)
  4. Remove GA4 tracking code
  5. Remove consent banner (if only used for analytics)

Step 5: Update Privacy Policy​

Replace cookie consent section with:

"We use Sealmetrics, a cookieless analytics platform, to understand how visitors use our website. Sealmetrics does not use cookies, does not store IP addresses, and cannot track you across different websites or visits. This processing is based on our legitimate interest in understanding website performance (GDPR Article 6(1)(f)). Data is retained for 25 months and stored exclusively in the EU. You can opt out at any time using our opt-out page."

Template available: Sealmetrics provides a complete privacy policy template to all customers.

Common Misconceptions About Cookieless Analytics​

Misconception 1: "Cookieless means less accurate data"​

Reality: Cookieless analytics is MORE accurate because you capture 100% of visitors, not just the 13-60% who accept cookies.

Data comparison (German e-commerce site, October 2024):

  • Google Analytics 4: 4,231 sessions
  • Sealmetrics (same site, same period): 32,487 sessions
  • Sealmetrics captured 7.7x more data

Misconception 2: "You can't track conversions without cookies"​

Reality: Cookieless analytics tracks conversions perfectly within a session. What you can't do is attribute conversions to specific users across multiple sessions—but GDPR makes that difficult anyway without consent.

Example: User visits Monday, returns Tuesday and converts. Cookie-based analytics (with consent) can connect these sessions. Cookieless analytics sees two separate sessions, but still captures the conversion. Attribution is different, not missing.

Reality: If properly implemented (like Sealmetrics), cookieless analytics requires zero consent in all EU countries under GDPR Article 6(1)(f) and CNIL guidance.

Country-specific notes:

  • Germany (TTDSG): Cookieless compliant, no consent needed
  • France (CNIL): Explicit guidance allowing cookieless without consent
  • Spain (AEPD): Follows CNIL interpretation
  • Netherlands: Cookieless exempt from cookie law

Misconception 4: "All analytics tools that claim 'no cookies' are equal"​

Reality: Many "cookieless" tools still:

  • Store hashed IP addresses (not GDPR anonymous)
  • Use localStorage (may still require consent)
  • Implement fingerprinting (illegal under GDPR)
  • Require consent "to be safe"

Only Sealmetrics provides true consentless analytics with zero IP storage and no persistent identifiers of any kind.

The Future of Web Analytics is Cookieless​

Browser vendors are killing third-party cookies:

  • Safari: Intelligent Tracking Prevention (ITP) blocks third-party cookies since 2017
  • Firefox: Enhanced Tracking Protection (ETP) blocks third-party cookies by default since 2019
  • Chrome: Third-party cookie deprecation planned for Q3 2024 (ongoing)
  • Edge: Following Chrome's timeline

Even first-party cookies face increasing restrictions:

  • Safari ITP: First-party cookies limited to 7 days storage
  • Firefox ETP: Partitioned first-party cookies in some cases
  • Brave: Aggressive cookie blocking by default

The trend is clear: Cookie-based tracking is ending, regardless of consent. Businesses that wait to adopt cookieless analytics will continue losing data.

Why Cookieless Analytics is the Answer​

Cookieless analytics solves both privacy concerns AND data accuracy:

  1. Privacy: No persistent tracking, no IP storage, no cross-site tracking
  2. Accuracy: 100% data capture, no cookie rejection losses
  3. Compliance: GDPR Article 6(1)(f) legitimate interest, no consent needed
  4. Performance: Smaller scripts, faster loads, no consent management overhead

Consentless analytics (Sealmetrics' approach) takes this further by designing the entire system to require zero consent under any circumstance.

Frequently Asked Questions​

Yes. Cookieless analytics is explicitly permitted under GDPR Article 6(1)(f) (legitimate interest) when properly implemented. CNIL's 2020 guidance confirms that analytics meeting specific criteria do not require consent.

No. If your analytics tool is truly cookieless (like Sealmetrics), you don't need a consent banner for analytics tracking. You may still need one if you use other cookies (advertising, social media, etc.).

3. How does cookieless analytics identify returning visitors?​

It doesn't. True cookieless analytics (like Sealmetrics) treats each visit as independent. You can see total return visitor percentage but cannot track specific individuals across sessions.

4. Can cookieless analytics track conversions?​

Yes. Cookieless analytics tracks conversions perfectly within a session. If a user visits and converts in the same session, you see the complete journey. If they return days later and convert, you see the conversion but cannot attribute it to the first visit.

These terms are used interchangeably. Both mean analytics that doesn't use cookies. However, some "cookie-free" tools still use other persistent identifiers (localStorage, fingerprinting) which may require consent.

6. Does cookieless analytics work with ad blockers?​

Partially. Sealmetrics' dual-system approach means:

  • JavaScript-enabled users: Tracked normally (session-based)
  • Ad blocker users: Tracked as isolated hits (no session connection)
  • Result: 100% of pageviews captured, but some session data lost for ad blocker users (~5% of traffic)

7. How accurate is cookieless analytics compared to Google Analytics?​

More accurate for traffic volume (100% capture vs 13-60%). Less detailed for user journey tracking across sessions. Overall, cookieless provides more complete data within the constraints of modern privacy regulations.

8. Can I use cookieless analytics and Google Analytics together?​

Yes, but it's redundant. Most businesses find that cookieless analytics provides all the data they need without GA's complexity and data loss. During migration, running both for 1-2 weeks helps verify data accuracy.

9. Does cookieless analytics affect SEO?​

No direct effect. However, removing consent banners (made possible by cookieless analytics) can reduce bounce rates by 10-15%, which may indirectly benefit SEO through improved user engagement metrics.

10. What about data retention with cookieless analytics?​

CNIL recommends 13 months maximum for analytics without consent. Sealmetrics retains data for 25 months based on documented legitimate interest (statistical analysis requires multi-year comparison). This is GDPR compliant when properly justified.

11. Is hashing IP addresses enough to be "cookieless"?​

No. Hashing IP addresses doesn't make them anonymous under GDPR (per Breyer vs Germany ECJ ruling). True cookieless analytics (like Sealmetrics) never stores IP addresses at all—not even hashed.

12. How does cookieless analytics handle bot traffic?​

Sealmetrics filters obvious bots (search engine crawlers, monitoring services) before tracking. Session-based tracking also naturally excludes most bot traffic since bots typically don't execute JavaScript properly.

13. Can I export data from cookieless analytics?​

Yes. Sealmetrics provides CSV exports and API access for raw data. You own your data completely and can export or delete it at any time.

14. What happens if GDPR rules change?​

Sealmetrics is designed to be compliant with the strictest interpretation of current GDPR, ePrivacy, and CNIL guidance. If regulations change, we update our approach immediately. Cookie-based tools are much more vulnerable to regulatory changes.

15. How does cookieless analytics work for mobile apps?​

Mobile apps don't use cookies, so "cookieless" is a web-specific term. For mobile apps, the equivalent is identifier-free tracking. Sealmetrics provides mobile SDKs that follow the same privacy-first principles: no device ID storage, no cross-session tracking, session-based analytics only.

Conclusion: The Cookieless Analytics Advantage​

Cookie-based web analytics is dying from two forces:

  1. Legal pressure: GDPR, ePrivacy, and aggressive enforcement make cookie consent increasingly complex
  2. Technical pressure: Browsers are blocking cookies regardless of consent

Businesses that continue using cookie-based analytics face:

  • 60-87% data loss from cookie rejections
  • Legal complexity managing consent across regions
  • Poor user experience from consent banners
  • Technical unreliability as browsers block more cookies

Cookieless analytics solves all these problems by eliminating cookies entirely.

Sealmetrics goes further with true consentless analytics:

  • 100% data capture (no cookie rejections)
  • Zero consent required (GDPR Article 6(1)(f) compliant)
  • No IP storage (more private than any competitor)
  • 2-minute setup (cookieless by default)
  • EU-hosted (no data transfers, no Schrems II concerns)

The future of web analytics is cookieless. The question isn't whether to make the switch, but how quickly you can implement it.

Additional Resources​

Learn more about cookieless analytics:

Legal and compliance:

Try Sealmetrics:

About the Author: This guide was written by the Sealmetrics team, creators of the leading consentless analytics platform. We believe accurate data and user privacy are not opposites—they're requirements for modern web analytics.

Last Updated: November 13, 2025

Sealmetrics captures 100% of your website traffic without cookies, consent banners, or IP address storage. GDPR compliant by design, trusted by privacy-conscious businesses across Europe.