Not a lawyer and haven't looked closely into the relevant statutes, but... My understanding is that so long as you're not a) using third-party cookies, or b) t

Not a lawyer and haven't looked closely into the relevant statutes, but... My understanding is that so long as you're not a) using third-party cookies, or b) trying to track the user beyond what's necessary for your site to function in a reasonable way (and that's "technical function", not "necessary for me to pay the bills for my site"), you don't need to have any banner. For instance, I run a small (and very niche) browser-based game, which has never done any advertising or tracking, not even Google Analytics. It needs a cookie to keep track of which account is logged in from any given browser, and another with a couple of per-device preferences for how the site should display, and that's it.