Based on recital 32, actions such as scrolling or swiping through a webpage or similar user activity will not under any circumstances satisfy the requirement of a clear and affirmative action:such actions may be difficult to distinguish from other activity or interaction by a user and therefore determining that an unambiguous consent has been obtained will also not be possible. Furthermore,in such a case, it will be difficult to provide a way for the user to withdraw consent in a manner that is as easy as granting it.

European Data Protection Board: Guidelines 05/2020 on consent under Regulation 2016/679