The Consent Management Regulation (EinwV), which came into force in April 2025, aims to reduce the flood of annoying cookie banners. Many internet users find these banners annoying and ineffective. Personal Information Management Systems (PIMS) are intended to remedy this situation. Based on Section 26 (2) of the Telecommunications Digital Services Data Protection Act (TDDDG), consent management services can be developed. The idea behind this is that instead of having to give consent on every website, a PIMS stores preferences and transmits them automatically. These services are reviewed and approved by the Federal Commissioner for Data Protection and Freedom of Information (BfDI). Now there could be new movement on this issue.
On October 17, 2025, “Consenter” became the first PIMS to be officially recognized. The plug-in was developed by the Berlin-based legal tech company Law & Innovation Technology, whose team works closely with research institutions such as the Berlin University of the Arts (UdK), the Einstein Center, and the Alexander von Humboldt Institute for Internet and Society (HIIG).
Whether PIMS will really make a breakthrough in practice is still uncertain. They face a number of challenges.
- Website operators are not bound to respect the consent signals of PIMS. Similar projects such as “Do Not Track” have failed in practice.
- Major browser manufacturers have not yet shown any interest in PIMS. Conflicts of interest may play a role here.
- The mere administration of consent does not pose a problem under data protection law. However, there is uncertainty regarding the prior determination of the respective controller. They must be known to the data subject before consent is given.
Our advice: Monitor developments, in particular whether critical market penetration is achieved, whether further PIMS are approved, and whether browser manufacturers follow suit. Until then, unfortunately, cookie banners remain the standard.