In its ruling in May 2020, the BGH decided how to obtain consent for cookies to be stored on end devices. As a result, website operators have to obtain the active consent of the users. Anyone who advertises via Google Ads should now get an idea of the tracking and their own campaign performance.

What did the BGH decide?

Advertisers have been familiar with these cookie banners since the introduction of the GDPR. Active consent is no longer just understood to be a purely informative banner. The storage of cookies must now be accepted (or rejected) at least with a click of the mouse. Pre-set checkboxes are not permitted because, according to the Karlsruhe judges, they do not represent active consent.

Saving cookies is necessary for Google Ads if conversions are to be measured. According to the current status, there is no conversion tracking without third-party cookies. Remarketing campaigns and campaigns for personalized advertising are even more dependent on cookies. Here, user target groups are formed by saving. Ads are then served to members of different audiences.

Impact on Google Ads performance

The new situation is quite different for every advertiser. The proportion of website visitors who opt-in or opt-out after clicking on an advertisement is likely to be different for different industries and for different forms of cookie banners. Online marketers should determine how high the corresponding user share is for their own website. The opt-in and opt-out components can be found in the backend of various cookie banners.

The fact that a certain proportion of the users of a website are not recorded is nothing new in itself. Various browsers with strict data protection settings and privacy plugins prevent tracking via Google Analytics, for example. As a result, it is not uncommon for the reports to show between 10% and 20% fewer users, conversions or sales.

As a result, the number of impressions and clicks will not change at the Google Ads account data level. However, fewer conversions can be recorded and assigned to Google Ads if the opt-out percentage now increases. This has direct effects, for example on smart bidding strategies, which may now have less conversion data available.

So there is a risk that Smart Bidding campaigns will concentrate on too small a user share and optimize bids too one-sidedly. This is less of a problem for advertisers who sell masses of products via Google Ads and can only serve a certain market share anyway. In smaller markets, local campaigns and accounts with a low conversion volume, however, this is advertising bypassing the real market.

What adjustments are conceivable?

Advertisers who place themselves in the latter scenario should check whether they see a decrease in conversions in the account after the cookie banner has been changed. Campaigns with the target CPA and target ROAS bid strategies run the risk of “over-optimizing”. So you should increase the target CPA or lower the target ROAS in order to still participate in a sufficient number of valuable auctions.

Remember: Smart bidding strategies work and learn with the conversion data they get. In reality, they may have more conversions from Google Ads than they can see in their account.

In order to prevent the account from concentrating only on the group of opt-in users through too strict settings, campaigns may be necessary to compensate for lost reach. These can be used in addition to the ongoing Smart Bidding campaigns in order not to endanger your search engine market share.

It should be crucial not to equip them with bid strategies that are geared towards conversions. Going all the way back to manual CPC shouldn’t be a good idea. The bid strategies remain auto-optimized CPC (eCPC), maximize the share of possible impressions or clicks. With clean A / B testing, a balance can be found between range and wastage. When setting up these campaigns, it is extremely important to focus on high-reach keywords that have led to conversions in the past.

What does the future of Google Ads tracking look like?

It has long been apparent that cookies are being phased out. The Mozilla Firefox and Safari browsers already completely block third-party cookies. Google’s Chrome will also follow suit by 2022 at the latest.

However, Google has already announced its own “privacy sandbox”. This can also be used to save user data, but as anonymous components of higher-level target groups. The web analysis should be consistently possible at a high level, as well as tracking and personalized advertising. It is already becoming apparent that the tech giant will thus occupy a special position in the online advertising landscape.

Google Ads also already offers options for placing your own target group advertising without the use of cookies. Semantic targeting enables ads to be served in the display network for keywords, topics or placements. Here, too, Google benefits from its market leadership as a search engine. The crawling and indexing of millions of websites offers an almost infinite selection of placements to reach a wide variety of target groups. The topic and content of the pages, as well as the search intentions of the users, serve practically as a target group source. Cookies are therefore not necessary for the placement of advertisements.

What do the cookie banners look like?

Various forms of cookie banners have appeared since the judgment of the ECJ in October 2019. Website operators should now indicate the types of cookies that could be stored on the user’s end devices in the corresponding banner.

Often several groups like “Essential”, “Marketing” and “External Media” are shown with checkboxes. In this example, cookies from Google Ads or Google Analytics fall under the “Marketing” category. If a user does not actively select this category, they may not be saved either. Often you come across an additional “accept all” button in the banner, which saves all cookies with a click of the mouse.

cookie banner


Advertisers should now definitely check whether they are offering a legally compliant variant of the opt-in for cookies. The proportion of users who opt out of statistics and tracking should be observed and interpreted. With this knowledge, fluctuations in conversions in the Google Ads account can be estimated.

Whether there is a need for optimization based on your own performance data differs for a wide variety of advertisers, websites, industries and campaign types. In general, overoptimization in Smart Bidding campaigns should be avoided if there is already little conversion data available.

If your own sales are dependent on remarketing or campaigns with personalized advertising, you may need to adapt your own advertising strategy. When doing web analysis, you should be aware that conversion data may be lower due to users opting out.


About the author

Philip Thomisch is Head of SEA at UnitedAds. He coordinates international campaigns and projects in the area of lead generation for clients.

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