New legal requirements are coming for online vendors this summer. In the B2C sector, most businesses will be required to implement a so-called ‘withdrawal button’ that allows customers to withdraw from a purchase directly through the online store. This requirement results from Directive (EU) 2023/2673. The goal? Make it even simpler for consumers to withdraw from contracts, although his is already pretty straightforward (and not subject to any burdensome formal requirements). And this has nothing to do with the cancellation button we’re already familiar with; the withdrawal button is actually mandatory for many more companies.
In Germany, this will be part of the updated German Civil Code (Section 356a) and take effect on 19 June 2026.
The withdrawal button requirement covers almost all online sales to consumers. The obligation applies regardless of whether the consumer purchases goods, digital content or services (including financial services). Exceptions apply only in cases where there is no right of withdrawal. Smaller businesses are not granted any special exemptions.
The legal requirements for the withdrawal button (or, as the lawmaker puts it, the withdrawal function) are quite specific:
First, there must be a clearly visible button labeled "Withdraw from contract here" (or equivalent wording). (The German law does not require the word “here”, contrary to the underlying EU directive). The button must be easily accessible, and available throughout the entire withdrawal period.
In a next step, the consumer must provide essential information to identify the contract:
Then, there must be a ‘confirmation button’ clearly labeled "Confirm withdrawal" or similar and equally clear.
Finally, businesses must immediately send the consumer a confirmation of receipt via e-mail (or other permanent record).
Companies offering subscriptions or ongoing services online in Germany might think this sounds familiar. You're right – it's similar to the cancellation button that's been required in Germany since July 2022 (Section 312k German Civil Code). However, unlike the withdrawal button, the cancellation button is not a requirement under EU law but German-specific. Even if a cancellation button has already been implemented, the requirement to provide a withdrawal button still applies. The legal consequences are also different: Cancellation (for instance, via the cancellation button) terminates the contract for the future, whereas in the case of withdrawal, the services already provided must (in principle, at least) be reversed.
19 June 2026 is less than three months away. Companies should move quickly to implement the withdrawal button if they haven't already initiated the process. Beyond the technical requirements, you'll also need to update your withdrawal policy and possibly your privacy policy. Non-compliance will almost certainly trigger warnings from competitors or consumer protection associations. Experience with the cancellation button (and other consumer laws) shows that consumer protection associations send out warnings shortly after new policies take effect and sometimes even provide consumers with ready-made reporting forms.
If you don't respond to such warnings within a few days, this can lead to interim injunctions or other legal action. Additionally, incorrect withdrawal policy information can prevent the withdrawal period from starting, meaning it won't expire until 12 months and 14 days have passed. Fines may also be imposed in some cases, though experience shows the risk of monetary fines is low in the beginning after a new regulation takes effect.
Beyond that, e-commerce law is constantly evolving. Businesses should monitor other regulatory developments: additional information requirements (such as durability guarantees) and legally required warranty labels. The Digital Fairness Act also promises to further strengthen consumer protection.
Daniel Trunk
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