For online "circulation", there are three choices: the two given above, plus the possibility that the "actual numbers" (e.g. generated from server logs) do not reflect what they appear to (ie. bot visits). This is "problem" that tracking seeks to fix, by avoiding a "circulation data source" (page visits) that isn't (and cannot be) reliable.
1. the current incentive where individual brands can defraud ad exchanges' pay-per-x systems. Without pay-per-x this incentive disappears.
2. publishers defrauding advertisers. This has similar cost & risk ratios online as either misreporting numbers or bulk-buying papers does in real life. There's also very little tangible difference between the ability of authorities or legal agents to enforce honest reporting of numbers online and in print. The two scenarios are eminently comparable.
Ultimately, removing pay-per-x brings online ads and the ability to defraud advertisers down to a level of equivalence with print.
Even in cases where the GDPR allows data collection for one purpose, that does not mean you can apply your collected data or analysis for a different purpose.
1. Collect data for DOS-prevention purposes.
2. Analyze it afterwards in aggregate for advertising purposes.
Except you can't do #2 without turning #1 into "collect data for DOS-prevention and advertising purposes", which goes beyond your legitimate interest in collecting the data.
I agree that #2 should be allowed if you'd do #1 anyway, but this isn't how the GDPR works.
Also...
> the circulation is not a secret
Isn't it? Like yes, there's a published figure, but is it verifiable?
If we're discussing potential for "fraud" here, I don't really see how there's any difference between online and print circulation.