A very similar problem was found and fixed in Nextcloud here https://github.com/nextcloud/server/pull/29758/files
Any news on this? This is a critical issue as it can have legal consequences and might not even be obvious to spot for all users of your plugin (one the developer has accepted the cookie info they are not expecting to see it and so will not notice that users are also not shown the banner…)
I am having the same problem. No popup is shown anymore. The popup is not even contained in the delivered page source with V12.3.6.1. This used to work until recently.