1) The "continue browsing" approach is not a valid mechanism to collect users' consent.
Some months ago, the AEPD considered scrolling down or clicking on a link on the website was expressing the user's consent - provided that the cookie banner was visible and that it clearly stated this. However, this was not aligned with the EDPB approach which considered that these were not valid ways to obtain consent. The AEPD has since agreed.
2) The use of "cookie walls".
These new criteria must be implemented by the end of October 2020, so organisations will have a short transitional period to introduce the necessary changes and to obtain consent according to the updated Guidance document.