From 19 June 2026, consumers must be able to withdraw contracts concluded via an online user interface directly through a withdrawal button – provided that a statutory right of withdrawal exists for the respective contract. What may initially appear to be a minor UI adjustment in fact affects the entire withdrawal process: withdrawal becomes a dedicated function embedded directly within the shop.
Legal Background
The obligation is based on an amendment to the EU Consumer Rights Directive (EU) 2023/2673.
Its objective is to provide consumers with a simple, clear and directly accessible digital withdrawal path – at the same location where the contract was concluded.
What matters is not the type of shop, but the specific contract:
The requirement applies to contracts concluded online with consumers, insofar as a statutory right of withdrawal exists.
What Changes With the Withdrawal Button Requirement From 2026?
Until now, withdrawals could typically be declared via email, contact form or customer service. These channels may continue to exist, but they will no longer be sufficient on their own.
From 2026 onwards, a mandatory digital withdrawal function within the shop itself will be required. This means that withdrawal becomes:
- Visibly integrated into the user guidance,
- usable without prior contact with customer support,
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and clearly standardized.
Who is Affected?
Affected are online contracts that are concluded with consumers via digital user interfaces and to which a statutory right of withdrawal applies - for example for goods, services, digital content or subscriptions.
Contracts without a statutory right of withdrawal arenot affected, e.g:
- fully provided services with an effective waiver,
- customized goods, provided that the statutory exclusion applies.
What Requirements Apply to the Implementation of the Withdrawal Button?
Although the regulation refers to a “button”, the legislator sets clear requirements regarding accessibility, process design and presentation:
- Not tied to a login:
Withdrawal must not depend on consumers having or using a customer account.
Withdrawal must also be possible directly within the shop in cases of guest orders. - Clear digital process:
After clicking the withdrawal button, a page must be provided where the necessary contract details can be entered. The withdrawal must then be actively confirmed and documented, including an acknowledgement of receipt sent by email. - Clear design and labeling:
The withdrawal button must be clearly visible, highlighted, accessible and clearly labelled (e.g. “Withdraw contract”). Misleading descriptions, unclear icons or hidden placement do not meet the statutory requirements.
According to the explanatory memorandum to the draft legislation, placement in the footer is not excluded per se, but requires clear visual emphasis and separation from other links.
These aspects demonstrate that compliance is not merely about placing a visible button, but about providing a low-threshold, clearly understandable and technically reliable withdrawal pathway.
Does the Withdrawal Button Have to Be Automatically Hidden After the Withdrawal Period Expires?
In practice, a common question arises as to whether the withdrawal button must be displayed or hidden individually for each customer depending on the specific withdrawal period applicable.
According to the explanatory memorandum to the draft legislation, such individualised control is not strictly required. If determining the exact withdrawal period for each individual case would involve disproportionate effort, the withdrawal function may be provided on a general basis. What remains decisive is that the withdrawal period is clearly communicated after conclusion of the contract and that the withdrawal button is available at least during the statutory withdrawal period. The mere display of the withdrawal button does not create any additional withdrawal rights beyond the statutory timeframe.
What Risks Arise From an Incorrect or Incomplete Implementation?
Implementation is more complex than it may initially appear. Beyond the visible function in the shop, it must be ensured that withdrawals are properly received, documented and integrated into existing processes – including guest orders.
Unclear or technically incomplete solutions may lead to legal risks. Early review and structured planning help avoid time pressure and ensure a stable implementation.
- cease-and-desist letters under competition law
- regulatory measures or administrative fines
- potentially an extension or renewed triggering of the withdrawal period
Conclusion: What Online Shop Operators Need to Consider Now
The withdrawal button is not merely a visual frontend element, but part of a legally defined process. The key requirement is that the function is accessible, transparent and properly embedded within the shop system.
We are happy to support you in integrating the statutory requirements into your existing shop architecture in a structured and technically robust manner.
The information provided by Blackbit is for general information purposes only. It does not constitute legal advice. For binding legal decisions, customers should consult a qualified lawyer.
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